Last modified on April 22, 2020
We collect Personal Information from users when they view, access, use or register through the Site or use any related services offered therein (collectively, “Services”). The provision of certain information is contractually required based on your use of the Services.
1. INFORMATION COLLECTED
(a) Our legal basis for collecting and processing your Personal Information is (i) your explicit consent when accessing the Services and (ii) a legitimate interest and need in order to provide specific Services offered on the Site, as described in our Terms of Service. We may collect the following Personal Information from users:
i. Information You Provide Voluntarily. We regularly receive and store any information you enter on the Site or give us in any other way, whether it be through filling out a form, or through an actual communication. You may elect to not provide certain information, but such an election may prevent you from taking advantage of, and accessing many of our features. We use the information that you provide for purposes such as: responding to your communications and/or requests, customizing future experiences on the Site for you, improving our stores, and communicating with you in any other way. The types of personally identifiable information which may be collected through your use of the Site include, but are not limited to: your name, physical address, any email address, phone numbers, fax numbers, billing address, shipping address, product selections or views, order and/or confirmation numbers, credit card numbers and expiration dates, referring URLs, IP addresses, passwords, usernames, gender, occupation, personal interests, your age and information about your hobbies, likes, interests in and regular use of certain products, programs and other services you use or may be interested in. You voluntarily provide the above personally identifiable information to us when you enter such information on the Site, whether input with the intention of facilitating a purchase, payment, newsletter subscription, promotion or contest and/or any other special offers or benefits. You are the source of this information.
ii. Information Provided Automatically. Upon your use or interaction with the Site, we automatically receive and store certain types of information. We obtain certain types of information when the browser you are using accesses the Site or advertisements therein, and other content served on the Site itself, or on behalf of the Site through other web sites.
· Non-Personal Information: We collect non-personally-identifying information of the sort that web browsers and servers typically make available upon their interaction with Sites. This information may include such things as the browser type used during the interaction, the language preference, the referring website, and the date and time of each visitor request.
· Your IP Address: Your Internet Protocol (“IP”) address is a unique identifying code which is used in connecting your computer to the Internet. Your IP Address may be used for various purposes, including to: (i) help us identify you, and your purchase orders, and to gather general and broad demographic information; (ii) help us diagnose or service technology problems that are associated with the IP addresses controlled by a specific Web company or ISP; (iii) help us estimate the total number of Users visiting the Site located in certain geographic locations; and (iv) help us determine which Users have access privileges or restrictions to certain content available on the Site.
· Device Identifier: We may provide services that allow Users to visit, view, access and customize the Site and other content through the use of their mobile devices such as: phones, PDAs and other similar electronic devices. When the Site is accessed through these devices rather than a computer, different information may be collected. When you visit or connect with the Site through the use of a mobile device that has Internet accessibility, in the event that the mobile device service provider uniquely identifies the device, we will be able to receive this identifying information. We may use this unique device information to be able to offer extended services and/or functionality. Certain services, offers you elect to enroll in, or purchases you wish to make through the Site may require the collection of the phone number for your device. We may associate and categorize the phone number collected along with the mobile device information.
· Your Physical Location: Some mobile phone service providers in the United States are required to operate using a certain functionality which pinpoints the physical location of any mobile devices currently using their service. Depending upon which service provider your device is enrolled with, and if you are visiting the Site while you are located in the United States, we may automatically receive this information. We may use and store such information received in order to assist us in providing opportunities for services based on your location, as well as to assist with advertising which is targeted based on location.
· Beacons: Web pages included on the Site may contain e-images called a “Web beacon,” also known as a “single-pixel GIF,” which allow a Site to count the number of Users who have visited that particular page or to access specific cookies and the information contained therein. We may use such Web beacons for the following purposes: (a) to count and determine the number of Users and to recognize such Users through the accessing of Site cookies, (b) to count, determine, and recognize the number of Users who have opened or read emails sent to the User by us, and (c) to assist in personalizing your interaction with the Site to make the experience more efficient and enjoyable for you.
THROUGH THIRD-PARTY SERVICES
may use certain third-party services in order to assist in the provision of the
Services to you, and to enhance your experience on the Site. Through your use of this Site, certain
portions of your information may be processed through the following third-party
service providers, and therefore, such processing shall be pursuant to the
terms and privacy policies of such third-party service providers. These third-party service providers may be
subject to change at any time, within the Company’s sole discretion:
i. Email Delivery
· Mailjet: https://www.mailjet.com/security-privacy/
· Mixpanel: https://mixpanel.com/legal/privacy-policy/
· App/Web Metrica: https://metrica.yandex.com/about/info/privacy-policy
· Google Analytics: https://policies.google.com/privacy
iii. Payment Services
· Stripe: https://stripe.com/privacy
iv. Login Services
· Facebook: https://www.facebook.com/about/privacy/
· Google: https://policies.google.com/privacy
· Kakao Talk: https://www.kakao.com/policy/privacy?type=sp&lang=en
3. SHARING AND USE OF PERSONAL INFORMATION
i. News; Offers. In some instances, we may provide certain personal information which you input while registering or signing up to receive news, offers, updates, sweepstakes or contests, to trusted, third-party partners who work directly with us. Such third-parties may use that personal information to communicate with you about certain updates, offers or surveys from us and/or such third-parties. If you wish to opt out of receiving such offers and/or materials, please email your desired request to opt out to: firstname.lastname@example.org.
ii. Independent Contractors and Third-Parties. We may have third-party agents, subsidiaries, affiliates and partners who may perform certain functions on our behalf, such as marketing, analytics, research, credit card processing, assisting with customer service, fraud protection, etc. Such third-party entities have limited access only to the personal information necessary to perform the roles for which they are associated with us. Such third-parties are strictly prohibited from using, selling, distributing or altering this data in any way, or using the information for any activity other than required to provide the requested services for us and the Site.
iii. Legal Disclosure. In some instances, we may disclose and release certain information in response to any legal demand, such as subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal actions or claims brought against us or the Site. We may share such information in order to investigate, prevent or take action in the event of any alleged illegal activities, suspected fraud, potential threats to the physical or financial safety of any person or entity, any violations of our terms of service, or as otherwise permissible under any applicable law.
vi. Some various ways in which we may use your Personal Information are as follows:
· To provide content, inventory access/features, and other various forms of information as it pertains to the Services.
· To verify your account and user identity and to comply with laws to which we are subject.
· To contact you about the Services or the Company.
· To provide customer or technical support.
· To analyze and improve the features and performance of the Services and to analyze usage patterns.
· To inform Users about offers from the Company.
4. THIRD PARTY LINKS
(a) You may encounter links to third party websites, videos, pictures, and applications (“Third-Party Links”) when using the Services. We cannot control the content on these Third-Party Links and we can make no guarantees as to the protection and privacy of any information which you submit to these Third-Party Links. Please exercise caution when accessing Third Party Links.
(a) We do not knowingly collect Personal Information from any child under the age of 13. Further, you may not use the Site unless you are at least 18 years of age. Please note that the Service is not for use by individuals under 18 years of age. You acknowledge and consent to taking such steps as are necessary in order to verify your identity and your age for the purposes of complying with applicable law, in order to use the Site. If you believe we have collected Personal Information from a child under the age of 13, please contact us immediately.
(a) We use commercially reasonable methods of protecting your Personal Information. Nevertheless, we cannot guarantee the safety or security of any Personal Information. Further, transmission of Personal Information cannot be made completely secure. For that reason, you agree to transmit Personal Information to the Company solely at your own risk.
7. DO NOT TRACK POLICY AND PROCEDURES
(a) We do not currently respond to “do not track” browser headers or specific “do not track” requests. You do have the ability to limit tracking through these third-party programs and by taking the actions listed below. The use of online tracking mechanisms by third-parties is governed by those third-parties’ own privacy policies, and not the terms included hereunder. If you prefer to prevent third-parties from setting and accessing cookies on your computer, you may adjust the settings of your own web browser to block the placement of cookies. You may remove yourself from the targeted advertising of companies by contacting the Network Advertising Initiative, or of companies participating in the Digital Advertising Alliance program by contacting them directly.
8. YOUR CALIFORNIA PRIVACY RIGHTS
(a) Supplemental Privacy Notice to California Residents:
i. If you are a resident of California, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Wild Tree Holdings, LLC or its subsidiaries to a third-party for the third-party’s direct marketing purposes. This right is granted to California residents and applies only to their activities within the State of California. To make such a request, please send an email to: email@example.com or write us at:
· BGPworks, Inc.
ATTN: CA Privacy Rights
216, 6, Wangsimni-ro 10-gil, Seongdong-gu, Seoul, Republic of Korea
ii. In your request, please specify the BGPworks company or subsidiary to which your request pertains. If no company is specified, we will treat your request as pertaining to BGPworks, Inc.
9. SHIELD ACT COMPLIANCE
(a) The safety and security of your private information is extremely important to us. As such, we have adopted and implemented reasonable safeguards to protect the security, confidentiality, and integrity of your private information. These safeguards are documented in our data security program which contains specific measures which we have undertaken to ensure the protection of your information. You may view a copy of our data security program here: https://www.heroku.com/policy/security, https://aws.amazon.com/security/. In the event of a suspected breach, to the extent we determine is required by applicable law in our sole discretion, we will provide notice of such a breach to you through any of the legally permissible methods of communication available to us. In the event of a determination being made that notification of a breach is not necessary, such determination will be documented and stored for the duration of the legally required time. For any further questions regarding our compliance with the Shield Act and your rights thereunder, please contact us at: firstname.lastname@example.org.
10. INTERNATIONAL PRIVACY PRACTICES
(a) The Company is primarily operated and managed on servers located and operated within the United States. In order to provide our Services to you, we may send and store your Personal Information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Information may be transferred outside of the country where you reside or are located, including countries that may not or do not provide the same level of protection for your Personal Information. We are committed to protecting the privacy and confidentiality of Personal Information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our Services, Users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of Personal Information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
11. RETENTION, CORRECTION, AND DELETION OF PERSONAL INFORMATION
(a) Personal Information that we process shall not be kept for longer than is necessary for the relevant purpose. We will retain your Personal Information as follows:
i. Personal Information will be retained for as long as you have a User Account (as described in our Terms and Conditions of Use) or as required by law or our own backup and security policies.
ii. We will comply with any user’s requests regarding access, correction, and/or deletion of the Personal Information we store in accordance with applicable law, including the EU General Data Protection Regulation (GDPR). To request that we correct, delete, or export any Personal Information, please contact us via email at email@example.com.
12. PERSONAL INFORMATION WILL BE SENT TO THE UNITED STATES
(a) The Company is based in the United States and your Personal Information will be processed in the United States. The hosting facilities for your Personal Information are in the United States. United States laws may be less strict than those of your own country.
13. YOUR RIGHTS UNDER THE EU GENERAL DATA PROTECTION REGULATION (GDPR)
(a) Your principal rights under the EU General Data Protection Regulation (GDPR) are as follows:
i. Right of Access: you have the right to be informed of, and request access to, the Personal Information we process about you.
ii. Right to Rectification: you have the right to request that we amend or update your personal data where it is inaccurate or incomplete.
iii. Right to Erasure: you have the right to have the Company delete your Personal Information.
iv. Right to Restrict: you have the right to request that we temporarily or permanently stop processing your Personal Information.
v. Right to Object: you have the right to object to us processing your Personal Information on grounds relating to your particular situation or for direct marketing purposes.
vi. Right to Data Portability: you have the right to request a copy of your Personal Information in electronic format and the right to transmit that personal data for use in another party’s service.
vii. Right not to be Subject to Automated Decision Making: you have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
14. DATA CONTROLLER AND HOW TO CONTACT US
(a) The Personal Information we collect and process is controlled by BGPworks, Inc., a Delaware corporation located in the United States. You may contact us at 216, 6, Wangsimni-ro 10-gil, Seongdong-gu, Seoul, Republic of Korea, or by email at: firstname.lastname@example.org.