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Privacy Policy

Privacy Policy

This Privacy Policy ("Policy") relates to our website at (the "Site"), and all related downloadable software, [mobile application] and otherservices provided by us and in or on which a link to this Privacy Policy isdisplayed, and all other communications with individuals by written or oralmeans, such as email or phone (collectively, together with the Site, (our"Service").

This Policy describes the information that [insert name of company] ("we" or "us") gatherson or through the Service, how we use and disclose such information, and thesteps we take to protect such information. By visiting the Site, or bypurchasing or using any Services, you consent to the privacy practicesdescribed in this Policy.

This Policy is incorporated into,and is subject to, our [Acceptable Terms of Use Policy] and our [Terms ofBusiness]. Capitalised terms used but not defined in this Policy have themeaning given to them in [our Terms of Business and our [Acceptable Terms ofUse Policy]


"Client" means a customer of ours.

"Client Data" means personal data, reports, addresses, and other files,folders or documents in electronic form that a User of any of our Servicesstores within the Service which would include but not be limited to [[] uploaded by a Client to our Site].

"Personal Data" means information that specifically identifies an individual orthat is linked to information that identifies a specific individual.

"Public Area" means the area of the Site that can be accessed both by Usersand Visitors, without needing to use a login ID and a password.

"Restricted Area" means the area of the Site that can be accessed only by Users,and where access requires the use of a login ID and a password.

"User" means a Client or an employee, agent, or representative of aClient, who primarily uses the restricted areas of the Site for the purpose ofaccessing the Service in such capacity.

"Visitor" means an individual other than a User, who uses the publicarea, but has no access to the restricted areas of the Site or Service.

The Information We Collect on the Service:

We collect different types ofinformation from or through the Service:

User-provided Information. When you use the Service, as a User or as a Visitor, you mayprovide, and we may collect Personal Data. Examples of Personal Data includename, email address, mailing address, mobile phone number, and credit card orother billing information. Personal Data also includes other information, suchas geographic area or preferences, when any such information is linked toinformation that identifies a specific individual. You may provide us withPersonal Data in various ways on the Service. For example, when you registerfor an Account, use the Service, post Client Data, interact with other users ofthe Service through communication or messaging capabilities, or send uscustomer service -related requests.

[Information Collected by Clients. A Client or User may store or upload into the Service ClientData. Each Client is responsible for providing notice to third personsconcerning the purpose for which the Client collects their Personal Data andhow this Personal Data is processed in or through the Service as part of ClientData].

"Automatically Collected" Information. When a User or Visitor uses the Service, we mayautomatically record certain information from the User's or Visitor's device byusing various types of technology, including cookies, "clear gifs" or "webbeacons." This "automatically collected" information may include IPaddress or other device address or ID, web browser and/or device type, the webpages or sites visited just before or just after using the Service, the pagesor other content the User or Visitor views or interacts with on the Service,and the dates and times of the visit, access, or use of the Service. We alsomay use these technologies to collect information regarding a Visitor or User'sinteraction with email messages, such as whether the Visitor or User opens,clicks on, or forwards a message. This information is gathered from all Usersand Visitors.

[Integrated Services. You may be given the option to access or register for theService through the use of your user name and passwords for certain servicesprovided by third parties (each, an "Integrated Service"), such as through theuse of your Google account, or otherwise have the option to authorise anIntegrated Service to provide Personal Data or other information to us. Byauthorising us to connect with an Integrated Service, you authorise us toaccess and store your name, email address(es), date of birth, gender, currentcity, profile picture URL, and other information that the Integrated Servicemakes available to us, and to use and disclose it in accordance with thisPolicy. You should check your privacy settings on each Integrated Service tounderstand what information that Integrated Service makes available to us, andmake changes as appropriate. Please review each Integrated Service's terms ofuse and privacy policies carefully before using their services and connectingto our Service.]

Information from Other Sources.

We may obtain information, includingPersonal Data, from third parties and sources other than the Service, such as [ourpartners, advertisers, credit rating agencies, and Integrated Services]. If wecombine or associate information from other sources with Personal Data that wecollect through the Service, we will treat the combined information as PersonalData in accordance with this Policy.

How We Use the Information We Collect

We use the information that wecollect in a variety of ways in providing the Service and operating ourbusiness, including the following:


We use the information other thanClient Data - to operate, maintain, enhance and provide all features of theService, to provide the services and information that you request, to respondto comments and questions and to provide support to users of the Service. Weprocess Client Data solely in accordance with the directions provided by theapplicable Client or User.


We use the information other thanClient Data - to understand and analyze the usage trends and preferences of ourVisitors and Users, to improve the Service, and to develop new products,services, features, and functionality.


We may use a Visitor's or User'semail address or other information other than Client Data to contact thatVisitor or User (i) for administrative purposes such as customer service, toaddress intellectual property infringement, right of privacy violations or otherissues related to the Client Data or Personal Data posted on the Service or(ii) with updates on promotions and events, relating to services offered by usand by third parties we work with. You have the ability to opt-out of receivingany promotional communications as described below under "Your Choices."

Cookies and Tracking Technologies

"Cookies" are text-only pieces ofinformation that a website transfers to an individual's hard drive or otherwebsite-browsing equipment for record-keeping purposes. Cookies allow the Siteto remember important information that will make your use of the Site moreconvenient. Please see our Cookie Policy for more information [insert link]

To Whom We Disclose Information

Except as described in this Policy,we will not intentionally disclose the Personal Data or Client Data that wecollect or store on the Service to third parties without the consent of theapplicable Visitor, User or Client. We may disclose information to thirdparties if you consent to us doing so, as well as in the followingcircumstances:

Unrestricted Information

Any information that you voluntarilychoose to include in a Public Area of the Service, such as [on a chat forum] [ora banner advertisement], [insert other as appropriate] will be available to anyVisitor or User who has access to that content.

Service Providers

[We work with third party serviceproviders who provide website, application development, hosting, maintenance,and other services for us. These third parties may have access to, or processPersonal Data or Client Data as part of providing those services for us. Welimit the information provided to these service providers to that which isreasonably necessary for them to perform their functions, and our contractswith them require them to maintain the confidentiality of such information]

Non Personally Identifiable Information

We may make certainautomatically-collected, aggregated, or otherwise non-personally-identifiableinformation available to third parties for various purposes, including (i)compliance with various reporting obligations; (ii) for business or marketingpurposes; or (iii) to assist such parties in understanding our Clients', Users'and Visitors' interests, habits, and usage patterns for certain programs,content, services, and/or functionality available through the Service.

Law Enforcement, Legal Process andCompliance

We may disclose Personal Data orother information if required to do so by law or in the good-faith belief thatsuch action is necessary to comply with applicable laws, in response to a courtorder, judicial or other government subpoena or warrant, or to otherwisecooperate with law enforcement or other governmental agencies.

We also reserve the right todisclose Personal Data or other information that we believe, in good faith, isappropriate or necessary to (i) take precautions against liability, (ii)protect ourselves or others from fraudulent, abusive, or unlawful uses oractivity, (iii) investigate and defend ourselves against any third-party claimsor allegations, (iv) protect the security or integrity of the Service and anyfacilities or equipment used to make the Service available, or (v) protect ourproperty or other legal rights, enforce our contracts, or protect the rights,property, or safety of others.

Transfer of Ownership

Information about Users andVisitors, including Personal Data, may be disclosed and otherwise transferredto an acquirer, successor or assignee as part of any merger, acquisition, debtfinancing, sale of assets, or similar transaction, as well as in the event ofan insolvency, bankruptcy, or receivership in which information is transferredto one or more third parties as one of our business assets and only if therecipient of the User or Visitor Data commits to a Privacy Policy that hasterms substantially consistent with this Privacy Policy.

Client Data may be physically orelectronically transferred to an acquirer, or successor or assignee as part ofany merger, acquisition, debt financing, sale of assets, or similartransaction, as well as in the event of an insolvency, bankruptcy, orreceivership in which information is transferred to one or more third partiesas one of our business assets, for the sole purpose of continuing the operationof the Service, and only if the recipient of the Client Data commits to aPrivacy Policy that has terms substantially consistent with this PrivacyPolicy.

Your Options

Access, Correction, Deletion

We respect your privacy rights andprovide you with reasonable access to the Personal Data that you may haveprovided through your use of the Services. If you wish to access or amend anyother Personal Data we hold about you, or to request that we delete anyinformation about you that we have obtained from an Integrated Service, you maycontact us as set forth in the "How to Contact Us" section. At your request, wewill have any reference to you deleted or blocked in our database.

You may update, correct, or deleteyour Account and or Account information and preferences at any time by [accessingyour Account settings page on the Service].[contacting us at [ ]. Please notethat while any changes you make will be reflected in active user databasesinstantly or within a reasonable period of time, we may retain all informationyou submit for backups, archiving, prevention of fraud and abuse, analytics,satisfaction of legal obligations, or where we otherwise reasonably believethat we have a legitimate reason to do so.

You may decline to share certainPersonal Data with us, in which case we may not be able to provide to you someof the features and functionality of the Service.

At any time, you may object to theprocessing of your Personal Data, on legitimate grounds, except if otherwisepermitted by applicable law.

This provision does not apply toPersonal Data that is part of Client Data. In this case, the management of theClient Data is subject to the Client's own Privacy Policy, and any request foraccess, correction or deletion should be made to the Client responsible for theuploading and storage of such data into the Service.

Navigation Information

You may opt out from the collectionof navigation information about your visit to the Site by [Google Analytics byusing the Google Analytics Opt-out feature.][or insert as appropriate]

Opting out from CommercialCommunications

If you receive commercial emailsfrom us, you may unsubscribe at any time by following the instructionscontained within the email or by sending an email to the address provided inthe ["How to Contact Us" section].

Users are able to view and modifysettings relating to the nature and frequency of promotional communicationsthat they receive from us by [contacting us using the unsubscribe option link containedwithin the email].

Please be aware that if you opt-outof receiving commercial emails from us or otherwise modify the nature orfrequency of promotional communications you receive from us, it may take up to [ten(10)] business days for us to process your request. Additionally, even afteryou opt-out from receiving commercial messages from us, you will continue toreceive administrative messages from us regarding the Service.

If a Client requests us to remove anydata, we will respond to its request within [fifteen (15) days. We will delete,amend or block access to any Personal Data that we are storing only if wereceive a written request to do so from the Client who is responsible for suchPersonal Data, unless we have a legal right to retain such Personal Data. Wereserve the right to retain a copy of such data for archiving purposes, or todefend our rights in litigation. Any such request regarding Client Data shouldbe addressed as indicated in the ["How to Contact Us"] section, and includesufficient information for us to identify the Client and the information todelete or amend.

Third-Party Services

The Services we provide may containfeatures or links to websites and services provided by third parties. Anyinformation you provide on third-party sites or services is provided directlyto the operators of such services and is subject to those operators' policies,if any, governing privacy and security, even if accessed through the Service.We are not responsible for the content or privacy and security practices andpolicies of third-party sites or services to which links or access are providedthrough the Service. We encourage you to learn about third parties' privacy andsecurity policies before providing them with information].

Your Privacy Rights

We will not share any Personal Datawith third-parties for their direct marketing purposes to the extent prohibitedby law. If our practices change, we will do so in accordance with applicablelaws and will notify you in advance.

Interest Based Advertising

Interest based advertising is thecollection of data from different sources and across different platforms inorder to predict an individual's preferences or interest and to deliver to thatindividual, or his/her computer, smart phone or tablet, advertising based onhis/her assumed preference or interest inferred from the collection of datapertaining to that individual or others who may have a similar profile orsimilar interests.

[We work with a variety of thirdparties to attempt to understand the profiles of the individuals who are mostlikely to be interested in our Services so that we can send them promotionalemails, or serve our advertisements to them on the websites and mobile apps ofother entities.

These third parties include: (a)advertising networks, which collect information about a person's interests whenthat person views or interacts with one of their advertisements; (b)attribution partners, which measure the effectiveness of certain advertisements;and (c) business partners [or insert as appropriate], which collect informationwhen a person views or interacts with one of their advertisements.

In collaboration with these thirdparties, we may collect information about our customers, prospects and otherindividuals over time and across different platforms when they use theseplatforms or interact with them. [Individuals may submit information directlyon our Sites or on platforms run by third parties, or by interacting with us,our advertisements, or emails they receive from us or from third parties. Wemay use special tools that are commonly used for this purpose, such as cookies,beacons, pixels, tags, mobile advertising IDs, flash cookies, and similartechnologies. We may have access to databases of information collected by ourbusiness partners].

The information we or third partycollect enables us to learn what purchases the person made, what ads or contentthe person sees, on which ads or links the person clicks, and other actionsthat the person takes on our Sites, or in response to our emails, or whenvisiting or using third parties' platforms.

We, or the third parties with whichwe work, use the information collected as described above to understand thevarious activities and behaviors of our customers, Site visitors and others.We, or these third parties, do this for many reasons, including: to recognisenew or past visitors to our Sites; to present more personalised content; toprovide more useful and relevant ads - for example, if we know what ads you areshown we can try not to show you the same ones repeatedly; to identify visitorsacross devices, third party websites and sites, or to display or sendpersonalized or targeted ads and other custom content that is more focused on aperson's perceived interest in products or services similar to those that weoffer.

Our interest-based ads may be servedto you in emails or on third-party platforms. We may serve these ads about ourproducts or services or send commercial communications directly ourselves orthrough these third parties.

Visitors may opt out of receivinginterest based advertising by advertising networks that may be delivered tothem on our platform and other websites by visiting the following websites: []

These features will opt a Visitorout of many but not all - of the interest-based advertising activities inwhich we or third parties engage.]

Third Party Cookies

We are legally required to disclosewhether other third parties may collect personally identifiable informationabout an individual's online activities from our Site or Service. Please seeour Cookie Policy for more information [insertlink].

The information gathered by thesethird parties is used to make predictions about your interests or preferencesso that they can display advertisements or promotional material on this Siteand on other sites across the Internet tailored to your apparent interests.

The business partners and advertisingnetworks that serve interest-based advertisements on the Services have limitedaccess to a small amount of information about your profile and your device,which is necessary to serve you advertisements that are tailored to yourapparent interests. It is possible that they may reuse this small amount ofinformation on other sites or services.

We do not share with these thirdparties any information that would readily identify you (such as emailaddress); however, these third parties may have access to information aboutyour device (such as IP or MAC address). We do not have access to, or controlover, the technologies that these third parties may use to collect informationabout your interests, and the information practices of these third parties arenot covered by this Privacy Policy. Other than as discussed in this document,we have no control over these third parties.

Minors' Privacy

Protecting the privacy of minors isespecially important. Our Service is not directed to minors under the age of 16,and we do not knowingly collect Personal Data from persons under the age of 16without obtaining parental consent. If you are under 18 years of age, thenplease do not use or access the Service at any time or in any manner. If welearn that Personal Data has been collected on the Service from persons under16 years of age and without verifiable parental consent, then we will take theappropriate steps to delete this information. If you are a parent or guardianand discover that your child under 18 years of age has obtained an Account onthe Service, then you may alert us at [] and request that we delete thatchild's Personal Data from our systems.

The Service is not intended to beused by minors, and is not intended to be used to post content to sharepublicly or with friends. To the extent that a minor has posted such content onthe Service, the minor has the right to have this content deleted or removedusing the deletion or removal options detailed in this Privacy Policy. If youhave any question regarding this topic, please contact us as indicated in the ["Howto Contact Us"] section. Please be aware that, although we offer thisdeletion capability, the removal of content may not ensure complete orcomprehensive removal of that content or information.

Data Security

We follow generally acceptedindustry standards to protect the information submitted to us, both duringtransmission and once we receive it. We use ISO certified cloud services andapplications. We maintain appropriate administrative, technical and physicalsafeguards to protect Personal Data against accidental or unlawful destruction,accidental loss, unauthorised alteration, unauthorised disclosure or access,misuse, and any other unlawful form of processing of the Personal Data in ourpossession. This includes, for example, firewalls, password protection andother access and authentication controls. We use TLS technology to encrypt dataduring transmission through public internet and ISO certified cloud servicesand applications, [and we also employ application-layer security features tofurther anonymise Personal Data.]


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