PRIVACY AND COOKIES POLICY
This is the Privacy and Cookies Policy for the website hosted at www.squip.com (“we“, “us” and “our site“) (the “Platform“). The Platform are operated by or on behalf of Squip Inc. We are committed to protecting and respecting your privacy.
This policy (together with our Terms and Conditions and any other documents referred to in it) sets out:
- Information we collect about you
- Cookies and other technologies
- How we use your information
- Our promotional updates and communications
- Who we give your information to
- Where we store your information
- Payment processing
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- Contact us
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
For the purposes of European data protection law, (the “Data Protection Law“), the data controller is: Attn: Squip 1809 W Frankford Road, Suite 160 Carrollton TX 75007 – e-mail: email@example.com
Information we collect about you
We will collect and process the following Personal Data from you:
- Information you give us
This is information about you that you give us directly when you interact with us.
This is information about you that you give us by filling in forms on our Platforms or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Platforms, subscribe to our service, search for a product, place an order on the Platforms, on or via our Platforms, enter a competition, promotion or survey, submit a query, and when you report a problem with our Platforms.
- Information we collect about you from your use of our Platforms: We will automatically collect information from you each time you visit our Platform. This includes:
- Technical information
- Information about your visit
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
- Personal Data of Children: As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Data from children under 16; if you are a child under 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at firstname.lastname@example.org.
Cookies and other technologies
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen will tell you how to do this. We also give you information about Disabling cookies. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Platforms and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, with your consent for non-essential cookies or where the cookie is strictly necessary/essential, because using them is in our legitimate interests (where we have considered that these are not overridden by your rights).
We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. These are necessary for our legitimate interests of enabling you to use our website. All other cookies will only be used if you have given your consent.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information with your consent subject to your choices and preferences to make our Platforms and the advertising displayed on it more relevant to your interests (as further set forth below). We may also share this information with third parties for this purpose.
We may also work with advertising networks that gather information about the content on our Platforms you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Platforms or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.
If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:
For Microsoft Internet Explorer:
- Choose the menu “tools” then “Internet Options”
- Click on the “privacy” tab
- Select the setting the appropriate setting
For Google Chrome:
- Choose Settings then Advanced
- Under “Privacy and security,” click “Content settings”.
- Click “Cookies”
- Choose Preferences then Privacy
- Click on “Remove all Website Data”
For Mozilla Firefox:
- Choose the menu “tools” then “Options”
- Click on the icon “privacy”
- Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
- Choose the menu Files then “Preferences”
Except for essential cookies, all cookies used on our site will expire after thirteen (13) months.
How we use your information
You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed below, under the heading ‘Purpose and lawful basis for processing of Personal Data.’
We use information held about you in the following ways:
- Information you give to us:
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- administering your account with us;
- notifying you about changes to our service.
- Provide you with information about our goods we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where that consent is required by law or, if it is not required by law, then in our legitimate interests provided these interests do not override your right to object to such communications. See ‘Our promotional updates and communications’.
- Ensure in our legitimate interests that:
- content from our Platforms is presented in the most effective manner for you and for your computer.
- we provide you with the information, products and services that you request from us.
- Information we collect about you from your use of our Platforms
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our Platforms safe and secure.
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To improve our Platforms to ensure that content is presented in the most effective manner for you and for your computer.
- To allow you to participate in interactive features of our service, when you choose to do so.
In some cases, provision of your information may be necessary to provide you with our Services. In these cases, if you fail to provide certain information when requested, we may not be able to give you access to our Services. In other cases, for example when we request your information so that we can send you marketing and promotional communications, if you do not provide the information we will not send you the marketing and promotional communications. We will specify the consequences of refusal to provide personal information at the time of the collection.
Our promotional updates and communications
Where permitted by law in our legitimate interest or with your prior consent, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products.
You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you.
Who we give your information to
We may give your information to:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of Personal Data in order to provide Services to you under this policy, where necessary for our legitimate interests, if we have considered these are not overridden by your rights. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
- Selected third parties. Our selected third parties may include:
- Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to your consent and the cookie section of this policy (this will not identify you as an individual).
- Payment processing providers who provide secure payment processing services. Note your payment card details are not shared with us by the provider.
- Other parties at your direction.
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
- Social media services (if you intentionally interact with them through your use of the Services).
- Third-party business partners who you access through the Services.
- Other parties authorized by you.
We will disclose your personal information to third parties:
- If Squip Inc. or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, regulation, process or governmental request, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Squip Inc., our customers, or others. This includes exchanging information with other companies and organizations, including law enforcement agencies, for the purposes of fraud protection and credit risk reduction and to prevent cyber or other suspected or alleged crime.
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.
- Performing services on our behalf, including [maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, control or was manufactured for us.
Where we store your information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) that may not be subject to equivalent Data Protection Law.
We may transfer your personal information outside the EEA, to the United States:
- In order to store it.
- In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS 1.3 (a strong protocol), X25519 (a strong key exchange), and AES_128_GCM (a strong cipher). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Platforms; any transmission is at your own risk. Once we have received your information, we will implement appropriate technical and organizational measures to protect your information from unauthorized access, loss, destruction or alteration.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain Personal Data for as long as you have an account with us in order to meet our contractual obligations to you and, where permitted by law, for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes. Local jurisdiction legal retention obligations remain unaffected. If you would like to know more about these, please contact us at email@example.com.
- You have the right under certain circumstances:
- to be provided with a copy of your Personal Data held by us;
- to request the rectification or erasure of your Personal Data held by us;
- to request that we restrict the processing of your Personal Data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your Personal Data, including the right to object to marketing communications, if applicable (as mentioned in ‘Our promotional updates and communications’ section);
- to request that your Personal Data be provided to you in a structured, commonly used and machine-readable format to transmit them to a third party;
- to provide instructions about your data after death.
- Your right to withdraw consent:
- Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org.You can also change your marketing preferences at any time as described in ‘Our promotional updates and communications’ section. In such case, you have the right to object to the processing of the data for direct marketing purposes through automated means and non-automated means. If you object to the processing of the data for marketing purposes, this will also apply to any processing of your personal information for profiling purposes to the extent that it is related to such marketing purposes. You can also object to the data processing for profiling purposes only.
You can also exercise the rights listed above at any time by contacting us at email@example.com
If your request or concern is not satisfactorily resolved by us, or you have another complaint regarding the data processing, where applicable, you may approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
Changes to this policy
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name, account and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
California Resident Rights
Sales of Personal Data
We have not sold your Personal Data over the last 12 months.
Additional information about the Personal Data we collect about you
Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed in the section “Who we give your information to” above:
- Personal identifiers.
- Customer records identified by state law.
- Commercial information.
- Internet or other similar network activity information.
- Geolocation data.
|Category of Personal Data||Personal Data Collected||What is the source of this Personal Data?|
|A. Personal identifiers Examples: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers.||Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.||You; our third party service providers|
|B. Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e))) Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number or any other financial information, medical information or health insurance information.||Name, address, telephone number.||You; our third party service providers|
|C. Commercial information Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||You; our third party service providers|
|D. Internet or other similar network activity information Examples: Browsing history, search history, or information on a consumer’s interaction with a website, application or advertisement.||Browsing history, search history, or information on a consumer’s interaction with a website, application or advertisement.||You; our third party service providers|
|E. Geolocation data Examples: Physical location or movements.||Geolocation.||You; our third party service providers|
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected from you. Under the California Consumer Privacy Act (“CCPA”), this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the personal about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a valid request to verify you and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Emailing us at email@example.com
- Submitting a form to this address: Attn: Squip 1809 W Frankford Road, Suite 160 Carrollton TX 75007
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may have different tiers of services as allowed by applicable data protection laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Purpose and lawful basis for processing of Personal Data
This table sets out:
- What Personal Data we process
- What we use that data for
- The lawful basis for the processing
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you (Art 6 (1) (1) (b) GDPR)|
|(a) To process and deliver your order (b) Manage payments, fees and charges (c) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (Art 6 (1) (1) (b) GDPR) (b) Performance of a contract with you (Art 6 (1) (1) (b) GDPR) (c) Necessary for our legitimate interests (Art 6 (1)(1) (f) GDPR: to recover debts due to us)|
|To enable you to partake in a prize draw or competition complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (Art 6 (1) (1) (b) GDPR) (b) Necessary for our legitimate interests (Art 6 (1) (1) (f) GDPR: to study how customers use our products, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (Art 6 (1) (1) (f) GDPR: for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation (Art 6 (1) (1) (c) GDPR)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (Art 6 (1) (1) (f) GDPR: to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To provide you with promotional updates and commercial communications by email about our products or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||(a) Necessary for our legitimate interests (Art 6 (1) (1) (f) GDPR: to develop our products/services and grow our business) (b) Consent|
|To keep our Platforms safe and secure||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (Art 6 (1) (1) (f) GDPR: for protecting our Platforms)|