Last modified: January 25th, 2020
Subify LLC (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website https://otcrew.com/ (our “Website”) and our practices for collecting, using, maintaining and organizing, protecting, deleting, and disclosing that information (collectively, “process” information). Some of this information may be considered “personal information” or “personal data” under applicable law, which is information that is about any individual, or from which any individual is identifiable (“personal information”).
This policy applies to information we collect:
On this Website.
In email, text, and other electronic messages between you and this Website.
Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
ANY OTHER SOURCES
It does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from
or on the Website
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any [personal] information to [or on] the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
[California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see [Your California Privacy Rights] for more information.]
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number or OTHER PERSONAL INFORMATION COLLECTED/any other identifier by which you may be contacted online or offline;
That is about you but individually does not identify you, such as INFORMATION EXAMPLES; and/or
About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website may include:
Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Your search queries on the Website.
DESCRIBE ANY OTHER TYPES OF INFORMATION THE USER PROVIDES
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Website, including traffic data, location data, logs,
and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
[We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here [INCLUDE AS LINK TO DO NOT TRACK DISCLOSURES] for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.]
The information we collect automatically [does/may/is only statistical data and does not] include personal information[, [but/or] we may maintain it or associate it with personal information we collect in other ways or receive from third parties]. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies)
. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
[We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.]
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.]
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.[
DESCRIBE ANY OTHER USES
In any other way we may describe when you provide the information.
For any other purpose with your consent.
[We may also use your information to contact you about [our own and third-parties’] goods and services that may be of interest to you. If you do not want us to use your information in this way, please [check the relevant box located on the form on which we collect your data (the [order form/registration form])/adjust your user preferences in your account profile.] For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.]
Disclosure of Your Information
We may disclose aggregated information about our users[, and information that does not identify any individual,] without restriction.
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business
and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Subify LLC
’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Subify LLC
about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients
For any other purpose disclosed by us when you provide the information.
With your consent.
ANY OTHER TYPES OF THIRD-PARTY DISCLOSURES.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Subify LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
If we engage third-party processors to process your personal information, such third-party processor will be subject to binding contractual obligations to: (i) only process the personal information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of your personal information; together with any additional requirement under applicable law.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies and Advertising
[Disclosure of Your Information for Third-Party Advertising
. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form/registration form)/OTHER OPT-OUT METHOD. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile, checking or unchecking the relevant boxes or by sending us an email with your request to firstname.lastname@example.org.
[Promotional Offers from the Company. If you do not wish to have your email address/contact information
used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form/registration form)/OTHER OPT-OUT METHOD or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to email@example.com.
If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by OPT-OUT METHOD. For this opt-out to function, you must have your browser set to accept all browser cookies.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
[California residents may have additional personal information rights and choices. Please see [Your California Privacy Rights] for more information.]
[Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: firstname.lastname@example.org.[However, please know we do not currently sell data triggering that statute’s opt-out requirements.]]
International transfer of personal information
Because of the international nature of our business, we may need to transfer your personal information to third parties as noted above, subject to binding contractual obligations (also considered “Standard Contractual Clauses”), solely in connection with the purposes set out in this policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Lawful Basis For Processing Personal Information.
In processing your personal information in connection with the purposes set out in this policy, we rely on one or more of the following legal bases, depending on the circumstances:
we have obtained your prior express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
the processing is necessary in connection with any contract that you may enter into with us;
the processing is required by applicable law;
the processing is necessary to protect the vital interests of any individual; or
we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
Your Legal Rights: Accessing, Updating, and Deleting Your Personal Information:
Subject to applicable law, you may have a number of rights regarding the processing of your personal information, including:
the right to request access to, or copies of, your personal information that we process or control;
the right to request rectification of any inaccuracies in your personal information that we process or control;
the right to request, on legitimate grounds:
erasure of your personal information that we process or control; or
restriction of process of your personal information that we process or control;
the right to object, on legitimate grounds, to the processing of your personal information by us or on our behalf;
the right to have your personal information that we process or control transferred to another independent data controller (as defined by applicable law), to the extent applicable;
where we process your personal information on the basis of your express consent, the right to withdraw that consent; and
the right to lodge complaints with a data protection authority regarding the processing of your personal information by us or on our behalf.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal information, please use the contact details provided in Section (19) below or, when appropriate, edit your account profile.
[Your California Privacy Rights]
[If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit [HYPERLINK TO CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS].
[California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at: Subify LLC, 185 Dorado Beach, East Dorado, Puerto Rico 00646, USA.]]
[We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. [All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions [and [OTHER INFORMATION]] will be encrypted [using SSL technology].]
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. [We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.]
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.]
We take every reasonable step to ensure that:
your personal information that we process is accurate and, where necessary, kept up to date; and
any of your personal information that we process that is inaccurate (having regard to the purposes of which they are processed) are erased and rectified promptly.
From time to time we may ask you to confirm the accuracy of your personal information.
We take every reasonable step to ensure that your personal information is limited to the personal information reasonably required in connection with the purposes set out in this policy.
We will only retain your personal information for as long as is necessary to fulfill our legitimate purposes, including for the purposes of providing our products and services to you and satisfying any legal, accounting, or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the information and the purposes of which it is kept and the potential risk of harm from unauthorized use or disclosure.
firstname.lastname@example.org [or via our toll-free number: [TOLL-FREE NUMBER]] [To register a complaint or concern, please [PRIVATE DISPUTE RESOLUTION INSTRUCTIONS].]