Privacy Policy
PRIVACY POLICY IMPORTANT: BY USING GOOBAY.COM'S
("COMPANY" OR "WE") SERVICES, INCLUDING WITHOUT LIMITATION
ANY OF ITS APPLICATIONS OR WEBSITES (THE "SERVICES") YOU CONSENT TO
THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT ALL PERSONAL
DATA (AS DEFINED UNDER REGULATION (EU) 2016/679 (GENERAL DATA PROTECTION
REGULATION) ("PII") THAT YOU SUBMIT OR THAT IS PROCESSED OR COLLECTED
THROUGH THE SERVICES MAY BE PROCESSED BY THE COMPANY IN THE MANNER AND FOR THE
PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH
HEREIN PLEASE DO NOT USE THE SERVICES.
SUMMARY
Information You Provide. If you
use the Services (defined below), we will need your PII (defined below) such as
your name, photo, address, e-mail address, phone number and your social network
or third party service provider user ID through which you registered/accessed
the Services
Information We Collect. We may
collect your PII from third parties (including without limitation, from social
media plug-in in the Services or from Third Party Platforms (defined below) you
interact with or access the Services from), communications you send us, and
aggregate data. We also automatically collect and record PII through your use
of the Services such as your IP address, IDFA identifiers, cookie information,
device ID and technical information regarding the method and nature of your use
of the Services. At any time, you may opt-out from receiving newsletters and
promotional communications from us.
How We Use Your Information. We
use your PII for purposes such as providing you with, improving and operating
the Services, understanding usage trends and user preferences, assisting users
with online purchasing decisions, personalising the Services and interest based
ads and in order to protect the Services from threatening activities.
Cookies, Web Beacons and Third Party
Processors. We use cookies to collect the information described in this
privacy policy, to manage and maintain the Services and to track your use of
the Services. We may also use web beacons, third party tracking technologies
and third party providers.
Links. The Services may contain
links to other services, sites and applications that are subject to their own
privacy and data protection policies.
Children. We do not intend to
collect PII from anyone we know to be under 13 years old. If you believe that
we might have collected such information, please contact us.
Information Sharing. We grant
access to your PII to our affiliates, representatives, agents, third party
service providers and business affiliates on whose website or platform you use
the Services. In addition, we may share your PII if required for the provision
and maintenance and improvement of the Services; to satisfy applicable law; to
prevent fraud or harm; to enforce agreements; or in the event of a merger,
acquisition or other structural change or form of sale of part or all of our
assets.
Information Security. We follow
generally accepted industry standards to protect against unauthorised access,
alteration, disclosure or destruction of your PII however we cannot guarantee
its absolute security.
Retention Periods. We retain your
PII as needed for the purposes for which it was collected and for lawful,
ethical and document retention purposes.
Data Integrity. We process PII
only for the purposes for which it was collected and take reasonable steps to
ensure that the PII we process is accurate, complete and current. However, we
depend on you to rectify your PII when necessary. We may delete or avoid from
recording and storing any information at our discretion.
Data Subjects' Rights. At any
time, you may contact us and request to exercise your rights in accordance with
applicable law. For more details see Section 9 below.
Enforcement. We will cooperate
with the appropriate regulatory authorities to resolve any formal written
complaints regarding processing of PII that cannot be resolved between us and
the complaining individual.
Consent to Processing and Transferring
of PII. Your PII may be stored and processed in a country outside the
country of your residence or from which you access the Services. Transfers of
your PII outside the EEA will comply with applicable laws.
Your California Privacy Rights and Do
Not Track Notices. If you are a California resident you may contact us and
request information regarding your PII disclosed to third parties for their
direct marketing purposes. We do not respond to Do Not Track signals.
Policy
1.
Information We Collect and How We Use It. In order to
provide and improve our Services, we may collect PII, including the following
types of information:
1.
Information You Provide. For some features of the
Services we ask you for personal information, including: name, photo, email
address, physical address, phone number, your social network or third party
service provider user ID through which you accessed or registered to the
Services (e. g. Facebook ID, hereinafter, "Third Party Platforms").
2.
Third Parties. We sometimes supplement the information
that you provide with information that is received from third parties. If you
access the Services through any Third Party Platforms, or interact with any
Third Party Platforms or other social media plug-in in the Services (such as a
Facebook "Like" button) we may receive information from your
respective social media or Third Party Platforms account, including your
account information, photo and any information defined as public pursuant to
the policies of such Third Party Platforms and/your settings in the respective
Third Party Platform.
3.
User Communications. When you send email or other
communication to the Company, we may retain those communications in order to
process your inquiries, respond to your requests and improve our Services. We
may send you push notifications to send you news and updates in respect of the
Services. We may also send you newsletters and promotional communications, you
may opt-out of this service at any time by submitting a request at the
following email address: contact@goobay.com
4.
Aggregated Personal Data. In an ongoing effort to better
understand and serve the users of the Services, Company often conducts research
on its customer demographics, interests and behaviour based on the PII and other
information provided to us. This research may be compiled and analysed on an
aggregate basis, and Company may share this aggregate data with its affiliates,
agents and business partners. This aggregate information does not identify you
personally. Company may also disclose aggregated user statistics in order to
describe our services to current and prospective business partners, and to
other third parties for other lawful purposes.
5.
User Information. When you use our Services, we may
automatically receive and record information from your device and browser,
including your IP address, IDFA identifiers (for iOS devices), Identifier for
Advertising (for iOS devices) and Google Advertiser IDs (for Android devices)
(such identifiers are collected herein for the following purposes, among other
things: frequency capping, attribution, conversion events, estimating the
number of unique users, advertising fraud detection, and debugging) cookie
information, search history, device ID, Android ID, your regional and language
settings, the physical location of your device (if you have permitted your
mobile or other location-aware device to transmit location data), network
status (WiFi/3G), and software and hardware attributes. We may use your
location (city) (if you have permitted your mobile or other location-aware
device to transmit location data) to learn how to adjust and personalise your
use of the Services. Our systems may automatically record and store technical
information regarding the method and nature of your use of the Services,
including without limitation which pages of the Services our visitors view and
impressions. An IP address is a numeric code that identifies your device
on a network, or in this case, the Internet. Your IP address is also used to
gather broad demographic information. The Company uses all of the PII that
we collect to understand the usage trends and preferences of our users. We also
use aggregate data for monetization.
6.
The Company uses all of the PII that we collect for
various reasons for example: We need the PII in order to provide or operate the
Services, including to provide customer support and process your requests,
questions and concerns; to understand the usage trends and preferences of our
users; assist our users with online purchasing decisions; using information to personalise content and features on our sites and the services; collecting our
services usage, analytics and performance data relating to our services, in
order to maintain, analyse, develop, update, and improve our products and
services; protecting against activities that may threaten the security,
integrity, or availability of our or another party’s products, systems, and
services; for personalising interest based ads; marketing and selling our
products and services; maintaining corporate or business records consistent
with our retention policies and applicable law. We also use aggregated data for
monetization.
2.
Cookies; web beacons and third party processors. In
order to collect the data described herein we may use temporary cookies that
remain on your device for a limited period of time. We may also use persistent
cookies that remain on your device until manually removed in the settings of
your device/browser, in order to manage and maintain the services and record
your use of the Services. Cookies by themselves cannot be used to discover the
identity of the user. A cookie is a small piece of information which is sent to
and stored on your device. Cookies do not damage your device.
Some of the cookies that we set when
you visit our Services are essential to the working functionality of the
Services. Performance cookies are another type of cookies uses to provide with
you a better user experience and to improve how content on our website is
presented.
Most browsers or devices may allow you
to block cookies block cookies but you may not be able to use some features on
the Services if you block them. You may set most browsers to notify you if you
receive a cookie (this enables you to decide if you want to accept it or not).
We may also use web beacons via the Services to collect information. Web
beacons or "gifs", are electronic images that may be used in our
Services or in our emails. We use Web beacons to deliver cookies, count visits
and to tell if and when an email has been opened and acted upon.
We also use third party tracking
technologies (including technologies of Rakuten Marketing LLC, Amazon Services
LLC and eBay Partner Networks Inc.'s), such as cookies and web beacons and
various third party providers to process and analyze your PII, profile end user
activities and provide targeted ads, including without limitation tracking your
use of the Services and third party services and sites. To learn more about
interest based ads and for certain opt-out options
Company is a participant in the Amazon
Services LLC Associates Program, an affiliate advertising program designed to
provide a means for sites to earn advertising fees by advertising and linking
to www.amazon.com.
3.
Links. Links to other services, sites and
applications may be provided by the Company as a convenience to our users. The
Company is not responsible for the privacy practices or the content of other
sites and applications and you visit them at your own risk. This privacy
statement applies solely to PII collected by us.
4.
Children. If you are a child under the age of 13,
you must obtain parental consent prior to using our Services. The Company
will not knowingly contact or engage with children under the age of 13 without
said parental consent. If you have reason to believe that a child has
provided us with their PII, please contact us at the email address contact@goobay.com and
we will endeavour to delete that PII from our databases.
5.
Information Sharing. As part of providing the Services
and/or generating and processing analytics, our affiliates, agent’s
representatives and third party providers may have access to your PII. The
Company may also share PII in the following circumstances: (a) as required for
the provision, maintenance and improvement of the Services; (b) if we become
involved in a reorganisation, merger, consolidation, acquisition, or any form
of sale of some or all of our assets; and/or (c) to satisfy applicable law or
prevention of fraud or harm or to enforce applicable agreements and/or their
terms, including investigation of potential violations thereof. The Services
may link to third party content, products and services. Any PII that you provide
in connection therewith is provided to a third party. We are not responsible
for the privacy and data protection practices of such third parties, or for
such content, products and services, and we encourage you to read the terms and
conditions and privacy policy of each third party that you choose to use or
interact with. Our business affiliates on whose website or platform you use the
Services will also have access to your PII. For more information about how they
collect and process PII please see their privacy policy on their website. We
require each of them to collect and process PII lawfully and to obtain your
consent where required.
6.
Information Security. We follow generally accepted
industry standards to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of PII. However, no method of
transmission over the Internet, or method of electronic storage, is 100%
secure. Therefore, while we strive to use commercially acceptable means to
protect your PII, we cannot guarantee its absolute security.
7.
Retention periods. We keep your PII only for as long
as reasonably necessary for the purposes for which it was collected or to
comply with any applicable legal or ethical reporting or document retention
requirements, and delete any PII that is no longer useful or relevant to our
operations.
8.
Data Integrity. The Company processes PII only for the
purposes for which it was collected and in accordance with this policy or any
applicable service agreements. We review our data collection, storage and
processing practices to ensure that we only collect, store and process the PII
needed to provide or improve our Services. We take reasonable steps to ensure
that the PII we process is accurate, complete, and current, but we depend on
our users to update or correct their PII whenever necessary. Nothing in this
policy is interpreted as an obligation to store information, and we may, at our
own discretion, delete or avoid from recording and storing any and all
information.
9.
Data Subjects' Rights
Right of Access and
Rectification. You have the right to know what PII we collect about you
and to ensure that such data is accurate and relevant for the purposes for
which Company collected it. We allow our users the option to access and obtain
a copy of their PII and to rectify such PII if it is not accurate, complete or
updated. However we may first ask you to provide us certain credentials to
permit us to identify your PII.
Right to Delete Personal Information
or Restrict Processing. You have the right to delete your PII or restrict
its processing. We may postpone or deny your request if your PII is in current
use for the purposes for which it was collected or for other legitimate purposes
such as compliance with legal obligations.
Right to Withdraw Consent. You
have the right to withdraw your consent to the processing of your PII.
Exercising this right will not affect the lawfulness of processing your PII
based on your consent before its withdrawal.
You may exercise the above rights by
sending a request to contact@goobay.com
Right to Lodge Complaint. You
also have the right to lodge a complaint with a data protection supervisory
authority regarding the processing of your PII.
Right of Data Portability. Where
technically feasible, you have the right to ask to transfer your PII in
accordance with your right to data portability
10. Enforcement. The
Company regularly reviews its compliance with this policy. Please feel free to
direct any questions or concerns regarding this policy or our treatment of PII
by contacting our data protection officer at dpo@goobay.com. When
we receive formal written complaints it is the Company's policy to contact the
complaining user regarding his or her concerns. The user may also lodge
complaint with relevant data protection authorities ,We will cooperate with the
appropriate regulatory authorities in accordance with applicable law, including
local data protection authorities, to resolve any complaints regarding the
processing of PII that cannot be resolved between the Company and an
individual.
11. Changes to This
Privacy Policy. We reserve the right, in our sole and absolute discretion, to
change this Privacy Policy at any time. Such change will be effective following
posting of the revised Privacy Policy on our Services, and your continued use
of our Services shall mean that you accept those changes.
We will notify you about significant
changes in the way we treat PII by sending a notice to the primary email
address specified in your account or by placing a prominent notice on the
Services. We encourage you to periodically review this policy for the latest
information about our privacy practices.
12. Consent To
Processing and Transferring of PII. By providing any PII to us pursuant to this
policy, all users, including, without limitation, users in the United States,
Israel ,member states of the European Union, and other regions, fully
understand and unambiguously consent to this policy and to the collection and
processing of such PII abroad. The server on which the Services are hosted
and/or through which the Services are processed may be outside the country from
which you access the Services and may be outside your country of residence.
Some of the uses and disclosures mentioned in this policy may involve the
transfer of your PII to various countries around the world that may have
different levels of privacy protection than your country. By submitting your
PII through the Services, you consent, acknowledge, and agree that we may
collect, use, transfer, and disclose your PII as described in this policy. If
you do not consent to the terms of this policy, please do not use the Services.
If we transfer your PII outside of the EEA we will, in the absence of an EC
Adequacy decision relevant to the destination country or to the transfer, seek
to rely on appropriate safeguards such as a valid Privacy Shield certification
(in the case of a data transfer to a Privacy Shield certified US recipient): https://www.privacyshield.gov/welcome,
or enter into appropriate EC approved standard contractual clauses (see https://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm)
13. Questions. If you
have any questions about this policy or concerns about the way we process your
PII, please contact our Data Protection Officer at dpo@goobay.com
14. Your California
Privacy Rights and Do Not Track Notices. California Civil Code Section
1798.83 permits customers of Company who are California residents to request
certain information regarding its disclosure of PII to third parties for their
direct marketing purposes. To make such a request, please contact us using the contact
details published on our Services. Please note that we are only required to
respond to one request per customer each year. You are also advised that
Company does not respond to “Do Not Track” signals.