Privacy Policy

Findwhere B.V. respects your privacy and is committed to protecting your personal information. This privacy notice tells you what types of information we collect about you when you visit our Site https://www.findwhere.com (the “Site”) and use our products and services or that we otherwise obtain directly from you or a third party, how we use that information, and in what instances we share your information. This privacy statement may change from time to time, so please check this policy periodically. For purposes of this privacy statement, the term “personal information” means any information that identifies you or identifies you in combination with other information.

Content

• Summary
• Our data
• If you visit our website
• If you use our website
• If you place an order
• Marketing Communications
• Information obtained from third parties
• Disclosure and other uses of your information
• How long we keep your information
• How we secure your information
• Transfer of your information outside the European Economic Area
• Your rights regarding your information
• Changes to our privacy policy
• Children’s privacy

Summary

This section summarizes how we obtain, store and use information about you.

It is intended as a very general overview. It is not complete by itself and should be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: Findwhere B.V. (based in the Netherlands)
• How we collect or obtain information about you:
  • Direct interactions via mail, phone, email, online or otherwise
  • Filling out a form on our Site requesting that we contact you:
  • Create an account on our Site:
  • Subscribe to our service or publications
  • Requests to send marketing to you
  • Enter a contest, promotion or survey: or give us feedback.
  • Data you upload to our Site. You may upload Content Data to our Site when you use our services.
  • Automated technologies or interactions. During your interaction with our Site, we may automatically collect technical data about your devices and usage data about your browsing actions and patterns. We collect this personal data through the use of cookies and other similar technologies.
• Information We Collect: We may collect, use, store and transfer various types of personal information about you that we have grouped below:
  • Identity information includes first name, maiden name, last name, username or similar identification and title.
  • Contact information includes billing address, e-mail address and phone numbers.
  • Transaction data includes details of payments to and from you and other details about products and services you have purchased from us, including the type of card used for a particular transaction (but no other card data).
  • Technical Data includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.
  • Profile information may include: your username, purchases or orders made by you, your job title, your occupation, your employer, feedback and survey responses.
  • Usage Data includes information about how you use our Site, products and services.
  • Marketing and communication data includes your preferences for receiving marketing from us and our third parties and your communication preferences.
  • Content Data includes any content you upload to the site or services such as comments and other text or images that contain personal data.

We collect, use aggregate data such as statistical or demographic data. Aggregate Data may be derived from your personal data, but is not legally considered personal data, as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users who access a specific Site feature. However, if we combine or link aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this Privacy Statement.

• How we use your data:We use your personal data only when permitted by law. Typically, we use your personal data in the following circumstances:
  • When we need to perform the contract we are going to or have made with you.
  • When it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not outweigh those interests.
  • When we must comply with a legal or regulatory obligation.

• Submission of your data to third parties: User data may be shared with partners for specific types of content and events where a user has registered their data. Other disclosures occur only to the extent necessary to run our business, to our service providers, to fulfill any contracts we may enter into with you, and when required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than as part of a business sale or purchase or similar event)? No, Findwhere B.V. does not sell any data. However, when you register or sign up for certain types of content, your registration data may be shared with sponsors and partners. Examples of where we do this are event registrations, webinar registrations or whitepaper downloads.

We will always make it clear where provided information is shared with other parties.

• How long we keep your data: no longer than necessary, taking into account our legal obligations (e.g., to keep records for tax purposes), other legal bases we have for using your data (e.g., your consent, performance of a contract with you, or our legitimate business interests), and certain additional factors described in the main section below entitled How long we keep your data. For specific retention periods regarding certain data we collect from you, please refer to the main section below entitled How long we keep your data.
• How we secure your data: using appropriate technical and organizational measures, such as storing your data on secure servers, encrypting the transfer of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or through our website using Secure Sockets Layer (SSL) technology, and granting access to your data only when necessary.
• Use of cookies and similar technologies: we use cookies and similar technologies to collect information such as marketing automation tracking on our website, including essential, functional, analytical and targeting cookies.
• Transfer of your data outside the European Economic Area: In certain circumstances, we may transfer your data outside the European Economic Area, including to the United States of America. When we do so, we provide appropriate safeguards, including, for example, that the third parties we use to transfer your data outside the European Economic Area have certified themselves as complying with the EU-US Privacy Shield.
• Use of profiling: we use profiling to better understand our users through web and marketing analytics, provide targeted advertising and ensure a personalized user experience.
• Your rights regarding your data
  • access to your data and information about its use
  • To have your data corrected and/or completed
  • To have your data deleted
  • To limit the use of your information
  • To receive your information in a portable format
  • To object to the use of your information
  • To withdraw your consent to the use of your data
  • file a complaint with a supervisory authority
• Sensitive Personal Information: we do not knowingly or intentionally collect what is commonly referred to as “sensitive personal information.” Please do not provide us with any sensitive personal information about you. For more information, see the main section below titled Sensitive Personal Information.

Our data

If you have any questions about this privacy policy, please contact the data controller.

Full name of legal entity: Findwhere B.V.
Title data protection administrator: Data protection representative
E-mail address: info@findwhere.com
Postal address: Findwhere B.V. Haaksbergweg 69 1101BR Amsterdam

You may contact the data protection officer by writing to our data protection officer at the above address or by sending an e-mail to info@findwhere.com.

When you visit our website

We collect and use website visitor information in accordance with this section and the Disclosure and Additional Use of Your Information section.

Our Web server automatically records the IP address you use to visit our Web site, as well as other information about your visit such as the pages visited, the information requested, the date and time of the request, the source of your access to our Web site (e.g., the Web site or URL (link) that referred you to our Web site), and your browser version and operating system.

Use of website server log information for IT security purposes

We collect and store server log files to ensure network and IT security and to ensure that the server and website remain unaffected. This includes analyzing log files to help identify and prevent unauthorized access to our network, the spread of malicious code, denial-of-service attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potentially criminal activity, we do not attempt, nor do we allow our hosting provider, to identify you from information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we are required by law to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk involved in our processing of information about individuals. Recording access to our website using server log files is one such measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your data to ensure network and information security.

Use of website server log information to analyze website usage and improve our website

We use the information collected by our Web server logs to analyze how our Web site users interact with our Web site and its features. For example, we analyze the number of visits and unique visitors we receive, time and date of visit, location of visit, and operating system and browser usage.

We use the information collected from the analysis of this information to improve our website. For example, we use the information collected to modify the information, content and structure of our website and individual pages based on what users are most engaged with and the length of time spent on particular pages of our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Justified interest: improving our website for our website users and learning about our website users’ preferences so that our website can better meet their needs and wants.

Cookies

Cookies are data files sent by a Web site to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and targeting cookies.

You can reject some or all of the cookies we use on or through our website by changing your browser settings or non-essential cookies using a cookie control tool, but doing so may affect your ability to use our website or some or all of its features. For more information about cookies, including how to change your browser settings, visit www.allaboutcookies.org or our cookie policy.

When you contact us

We collect and use information from individuals who contact us in accordance with this section and the Disclosure and Additional Use of Your Information section.

Email

When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, phone number and the information in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: answering questions and messages we receive and maintaining correspondence.

Legal basis for processing: necessary to perform a contract or to take steps to enter into a contract at your request (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: when your message relates to us providing you with goods or services or taking steps at your request prior to providing our goods and services (for example, providing information about such goods and services), we process your data to do so).

Application forms

When you contact us through an inquiry form, we collect your personal information and compare it to the information we have about you. Typically personal information collected includes your name and contact information. We also record the time, date and the specific form you filled out.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your inquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: answering questions and messages we receive and maintaining correspondence.

We will also use this information to coordinate any follow-up sales and marketing communications with you. For more information, see the section of this privacy policy entitled “Marketing Communications.

Messages you send us through our contact form are stored within the European Economic Area on the servers of our contact form provider in the Netherlands.

Phone

When you contact us by phone, we collect your phone number and any information you provide during your conversation with us.

We record customer-facing phone calls for training and customer service.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: answering questions and messages we receive and maintaining correspondence.

Legal basis for processing: necessary to perform a contract or to take steps to enter into a contract at your request (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: when your message relates to us providing you with goods or services or taking steps at your request prior to providing our goods and services (for example, providing information about such goods and services), we process your data to do so).

Post

If you contact us by mail, we collect all the information you provide in any postal messages you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: answering questions and messages we receive and maintaining correspondence.

Legal basis for processing: Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: when your message relates to us providing you with goods or services or taking steps at your request prior to providing our goods and services (for example, providing information about such goods and services), we process your data to do so).

When you use our website

We collect and use information from individuals who interact with certain features of our website in accordance with this section and the Disclosure and Additional Use of Your Information section.

Newsletters

When you subscribe to one of our newsletters by completing the newsletter subscription form, we collect your name, email address. We also record the time and date of completion.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you authorize us to send you our newsletters by signing up to receive them through the steps described above.

We will also use this information to coordinate any follow-up sales and marketing communications with you. For more information, see the section of this privacy policy entitled “Marketing Communications.”

Transfer and storage of your information

We use a third party to send our e-newsletter and manage our mailing list, Zoho.

Information you provide to subscribe to our e-newsletter may be stored outside the European Economic Area on the servers of our third-party mailing list provider in the United States.

For more information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this Privacy Policy below entitled Transferring Your Information Outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to enable us to assess the level of engagement with our emails by measuring information such as delivery rates, opening rates, click-through rates and engagement with the content our emails reach.

Register on our website

When you register and create an account on our websites, we collect the following information: your name, e-mail address, address, place of residence. We also record the time and date of completion.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Justifiable interest: registering and managing accounts on our website to provide access to content, allows you to purchase goods and services, and facilitates the running and operation of our business.

We will also use this information to coordinate any follow-up sales and marketing communications with you. For more information, see the section of this privacy policy entitled “Marketing Communications.”

Transfer and storage of your information

Information you provide us through the registration form on our website is stored within the European Economic Area on the servers of our third-party hosting provider in London.

When you place an order

We collect and use information from individuals who place an order on our website in accordance with this section and the Disclosure and Additional Use of Your Information section….

Information collected when you place an order

Required information

When you place an order for goods or services on our Web site, we collect your name, e-mail address and billing address.

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we are required by law to invoice you for the goods and services you purchase from us when you are subject to VAT and we need the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.

Additional information

We may also collect additional information from you, such as your phone number, full name, address, etc.

We use this information to manage and improve your customer experience with us.

We will also use this information to tailor your sales and marketing communications. For more information, see the section of this privacy policy entitled “Marketing Communications.

If you do not provide the additional information requested at checkout, you will not be able to complete your order because we will not have the correct information to adequately manage your account.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: The ability to provide adequate customer service and management of your customer account.

Marketing Communications

Our content, goods and services

When you sign up for content, register on our website or make a payment, we use the information you provide to contact you about related content, products and services.

We will continue to send you marketing communications regarding similar goods and services if you do not choose not to receive them.

You may opt out of receiving marketing communications at any time by sending an e-mail to info@findwhere.com.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information about related business services, to help your organization grow, or to further develop you as a professional.

Transfer and storage of your information

We use a third party to send our marketing emails and manage our mailing list, Zoho.

Information for marketing campaigns may be stored outside the European Economic Area on the servers of our third-party mailing list provider in the United States.

For more information about the safeguards used when your data is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transferring your data outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphics files) and tracked links in the emails we send to enable us to assess the level of engagement with our emails by measuring information such as delivery rates, opening rates, click-through rates and engagement with the content our emails reach.

third-party goods and services

In addition to receiving information about our products and services, you may choose to receive marketing communications from us related to third-party goods and services by email by checking a box that you wish to receive such communications.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you authorize us to send you information about third-party goods and services by signing up to receive such information in accordance with the steps described above.

Transfer and storage of your information

We use a third-party service to send our marketing emails and manage our mailing list, Mailchimp.

Information for marketing campaigns is stored outside the European Economic Area on the servers of our third-party mailing list provider in the United States.

For more information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this Privacy Policy below entitled Transferring Your Information Outside the European Economic Area.

Use of tracking in emails

We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement with our emails by measuring information such as delivery rates, open rates, click-through rates and engagement with the content our emails reach.

Information obtained from third parties

This section explains how we obtain or collect information about you from third parties.

Information obtained from third parties

We often receive information about you from third parties. The third parties from whom we receive information about you may include partner events within the marketing industry and other organizations with which we have professional affiliations.

It is also possible that third parties with whom we have not previously had contact may provide us with information about you.

The information we receive from third parties is generally your name and contact information, but also includes any additional information about you that they provide to us.

Legal basis for processing: necessary to perform a contract or take steps to enter into a contract at your request (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: when a third party has submitted information about you to us (such as your name and email address) so that we can provide services to you, we process your data to take steps at your request to enter into a contract with you and perform a contract with you (as appropriate).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: where you have asked a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your data based on your consent, which you give by asking the third party in question to transfer your data to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, in certain circumstances we have a legitimate interest in processing that information.

For example, we would have a legitimate interest in processing your information to perform our obligations under a subcontract with the third party when the third party has the prime contract with you. Our legitimate interest is the performance of our obligations under our subcontract.

Similarly, third parties may disclose information about you to us if you have infringed or may have infringed any of our legal rights. In that case, we have a legitimate interest in processing that information to investigate and prosecute such potential infringement.

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we have about you or to obtain missing information we need to provide you with a service), we will obtain information about you from certain publicly available sources, both inside and outside the EU, such as Companies House, online customer databases, business directories, media publications, social media and websites (including your own website if you have one.

In certain circumstances, we will also obtain information about you from private sources, both inside and outside the EU, such as marketing data services.

We will continue to send you marketing communications regarding similar goods and services if you do not opt out.

You may opt out of receiving marketing communications at any time by sending an e-mail to info@findwhere.com.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: Sharing relevant, timely and industry-specific information about related business services, to help your organization grow, or to further develop you as a professional.

When we improperly receive information about you

If we mistakenly receive information about you from a third party and/or we do not have a legal basis for processing that information, we will delete your information.

Amendment and additional use of your data

This section describes the circumstances in which we disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use some third parties to provide us with services necessary to run our business or to help us run our business.

These include the following: Internet services, IT service providers and web developers.

Our external service providers are located both inside and outside the European Economic Area.

Your information is shared with these service providers when necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not publicly disclose the identity of our service providers for security and competitive reasons. However, if you would like more information about the identity of our service providers, please contact us directly by email and we will provide you with such information when you have a legitimate reason to request it (e.g., when we have shared your information with such service providers).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest invoked: when we share your data with these third parties in a context other than as necessary to perform a contract (or take steps to do so at your request), we will share your data with these third parties to enable us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps at your request before we enter into a contract with you.

Disclosure and use of your information for legal reasons

Inform a competent authority of possible criminal acts or threats to public safety

If we suspect criminal or potential criminal conduct, we may need to contact an appropriate authority, such as the police, in certain circumstances. This could be the case, for example, if we suspect that fraud or a cybercrime has occurred or if we receive threats or malicious communications against us or third parties.

Generally, we only need to process your data for this purpose if you are in any way involved or affected in such an incident.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Justified interests:preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or possible enforcement of our legal rights

We will use your information in connection with the enforcement or possible enforcement of our legal rights, including, for example, sharing information with collection agencies if you do not pay amounts owed to us while you are contractually obligated to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights we have under copyright or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Justified interest:enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceeding.

We may need to use your information if we are involved in a dispute with you or a third party, for example to resolve the dispute or as part of a mediation, arbitration, court or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Justified interest: resolving disputes and potential disputes.

How long we keep your data

This section explains how long we keep your data. Where possible, we have established specific retention periods. Where that was not possible, we have explained the criteria we use to determine the retention period.

Retention periods

Server log information: we keep information on our server logs for 3 months.

Order information: when you place an order for goods and services, we retain that information for seven years after the end of the fiscal year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and inquiries: when you ask a question or correspond with us for any reason, either by e-mail or through our contact form or by phone, we will retain your information for as long as necessary to answer and resolve your question, and for another 36 months, after which we will archive your information.

Newsletter: we retain the information you used to subscribe to our newsletter for as long as you remain subscribed (i.e., you do not unsubscribe).

Subscription: we retain the information you used to sign up for our subscriptions for as long as you remain subscribed (i.e., you do not unsubscribe).

Criteria for determining retention periods

In all other circumstances, we will not keep your information longer than necessary, taking into account the following:

• The purpose(s) and use of your information now and in the future (such as whether it is necessary to keep that information in order to continue to fulfill our obligations under a contract with you or to contact you in the future);
• Whether we have a legal obligation to continue processing your information (such as record-keeping obligations under relevant laws or regulations);
• Whether we have a legal basis to continue processing your data (such as your consent);
• How valuable your information is (both now and in the future);
• Any relevant agreed-upon industry practices on how long information should be retained;
• The degree of risk, cost and liability if we continue to hold the information;
• How difficult it is to ensure that information can be kept current and accurate; and
• any relevant environmental conditions (such as the nature and status of our relationship with you)].

How we secure your information

We take appropriate technical and organizational measures to secure and protect your information from unauthorized or unlawful use and accidental loss or destruction, including:

• Only share and provide access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymous basis whenever possible;
• The use of secure servers to store your information;
• verifying the identity of any person requesting access to information before granting them access to information;
• The use of Secure Sockets Layer (SSL) software to encrypt payment transactions you make on or through our website;
• only transfer of your information through a closed system or encrypted data transmission;

Transmission of information to us via e-mail

The transmission of information over the Internet is not completely secure, and if you provide information to us over the Internet (by e-mail, through our website or by any other means), you do so entirely at your own risk.

We will not be responsible for any costs, expenses, loss of profits, loss of reputation, damages, liabilities or any other form of loss or damage you suffer as a result of your decision to disclose information to us in such manner.

Transfer of your information outside the European Economic Area

Your information may be transferred and stored outside the European Economic Area (EEA) in the circumstances set forth earlier in this policy.

We will also transfer your data outside the EEA or to an international organization to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protection.

Your rights regarding your data

Subject to certain limitations on certain rights, you have the following rights with respect to your information, which you may exercise by writing to the data controller using the information at the top of this policy.

• request access to your data and information about our use and processing of your data;
• To request the correction or deletion of your data;
• To request that we limit the use of your information;
• To receive information you have provided to us in a structured, commonly used and machine-readable format (e.g., a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
• To object to the processing of your data for certain purposes (for more information, see the section below entitled Your right to object to the processing of your data for certain purposes); and
• to withdraw your consent to the use of your data at any time when we rely on your consent to use or process that data. If you withdraw your consent, this will not affect the lawfulness of our use and processing of your data based on your consent prior to the time you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or of an alleged breach of the General Data Protection Regulation.

Further information about your rights regarding your personal data as an individual

More information about your rights and the restrictions on those rights can be found in the underlying legislation in Articles 12 to 22 and 34 of the General Data Protection Regulation, available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf.

Verification of your identity when you request access to your data

When you request access to your data, we are required by law to take all reasonable steps to verify your identity before doing so.

These measures are designed to protect your data and reduce the risk of identity fraud, identity theft or general unauthorized access to your data.

How we verify your identity

When we have appropriate information about you, we will attempt to verify your identity from that information.

If it is not possible to identify you from such information, or if we do not have sufficient information about you, we may require original or certified copies of certain documentation to verify your identity before we can grant you access to your information.

If and when you make such a request, we can confirm exactly what information we need to verify your identity in your specific circumstances.

Your right to object

You have the following rights with respect to your information, which you can exercise in the same way you can exercise them by writing to the data controller using the details at the top of this policy.

• to object to the use or processing of your information when we use or process it to perform a task in the public interest or for our legitimate interests, including “profiling” (i.e., analyzing or predicting your behavior based on your information) based on any of these purposes; and
• To object to the use or processing of your information for direct marketing (including any profiling we perform that relates to such direct marketing).

You can also exercise your right to object to the use or processing of your data for direct marketing by:

• click on the unsubscribe link at the bottom of any marketing email we send you and follow the instructions that appear in your browser after you click on that link;
• Send an e-mail to info@findwhere.com asking us to stop sending you marketing communications or stating the words “OPT OUT.”

Sensitive personal information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or membership in a trade union, genetic information, biometric information for the unique identification of an individual, health information, or information about a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you should not provide us with sensitive personal information.

However, if you accidentally or intentionally provide us with sensitive personal information, you will be deemed to have expressly consented to the processing of that sensitive personal information by us under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information to delete it.

Changes to our Privacy Policy

We update and modify our Privacy Policy from time to time.

Minimal changes to our Privacy Policy

When we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date listed at the beginning of it. Our processing of your information will be governed by the practices set forth in that new version of the Privacy Policy as of the effective date.

Major changes to our Privacy Policy or the purposes for which we process your data

If we make significant changes to our Privacy Policy or intend to use your information for a new purpose or a purpose other than that for which we originally collected it, we will notify you by email (if possible) or through a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your data for that new purpose.

Where necessary, we will seek your prior consent before using your data for a purpose other than that for which we originally collected it.

Privacy of children

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its regulations protect the privacy of children using the Internet. We do not knowingly access or collect information from individuals under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that, through fraud or deception by third parties, we may receive information about persons under the age of 18. If we are notified, once we have verified the information, if required by law, we will promptly obtain appropriate parental consent to use the information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you wish to notify us of our receipt of information about persons under the age of 18, please contact us using the details at the top of this policy.