Why so much text?
Ok, so why should I care?
Because we love you! No really. Anyway, this Policy is telling you your privacy rights that, as our beloved client, you have. If you do not need or do not want to use our Site or our email and newsletter services, please close this web tab and exit the Site (bye bye!). If you really want to stay, then you got to hear this: the words “use”, “collect”, “treat”, “process” and “disclose” are not just things we do with the information that you give us, but they have deep meanings when related to personal information and other data (our attorneys told us to put it here, really).
Rules of the game.
Now it gets better. We may change and updated our Policy at any time and we strongly suggest that you revise it back frequently for any updates. It is like a football game where the referee can change the rules at any moment! Why? Because it would be unpractical to have every one of our users to sing the Policy and each time it changes. We will post the update on the Site, don’t worry, and we will send you an email (that’s what we do by the way). We reserve the right to update the Site, usually to make it better and shiner and nicer. Your simple use of our Site and the email and newsletter services it offers indicates that you accept our Policy.
Won't someone think of the children?
As a matter of fact, we do. In compliance with the terms and conditions of the Children’s Online Privacy Protection Act (‘COPPA’), Rabbut does not (knowingly) collect any kind of information from any person under the age of thirteen (13). We will delete any data associated for which we obtain actual or purported knowledge that is associated with someone who is not at least thirteen (13) years old.
Persons under the age of eighteen (18) may only use our Site under the direct supervision of their adult guardian or parent. If you are still a minor (this may depend on the jurisdiction where you reside), you must be under the direct supervision of your parent or legal guardian before using our Site.
Ok, you got my attention, tell me more.
In order for you to receive our services and for us and our partners, licensors, suppliers and affiliates to help us provide them to you, we will need to collect personally identifiable information from you, including but not limited to: name, address and email address. You represent and warrant to us that you have due authorization for every single bit of information you give us. And you better have it.
Accordingly, we will maintain the safety and integrity of your personal information, and will enforce your individual rights to access and correct your personal information. We stand by our word.
We may also collect certain personally identifiable information from you when you log in to our Site through the functionality of using your credentials with social media and, in such cases, we will not collect more information about you from these accounts beyond the personal information such third party service providers release to us.
Who controls my information?
We continuously try to improve our user experience, in order to give you the best choices for editing or removing your personally identifiable information collected by us. Generally, you will be able to select the amount and type of information you provide to us when using our Site, usually in the settings section of your account.
So, who will know my information?
We will not sell any of your information to anyone (including, of course, email lists), and we will take all commercially reasonable steps to safeguard your information (like, you know, from evil hackers). We use industry standard safety measures to protect your information from unauthorized access, including secure hardware and software (the expensive type).
Still we may need to disclose/release your information when we believe you to be in breach of our Terms our Policy, or if any of the quite unfortunate circumstances occurs:
- If some obscure law obliges us (our attorneys will know, those guys);
- If the police, FBI, God or other law enforcement agency ‘asks’ us to do so;/li>
- To defend ourselves from legal claims by third parties and to respond to such claims (including takedown notices and subpoenas);
- To protect the property, rights and integrity of Rabbut or any third party (yeah!);
- To prevent or terminate activities we may consider to be -- or which me may consider to pose a risk -- of any illegal, unethical or objectionable activity (we are always looking after our customers);
- To our affiliate, subsidiary or holding companies, which may use your information to help us provide and improve our wonderful products and services.
So, in the digital world, there are no frontiers any more. Right? Well, a company has to operate in some place, and in the case of Rabbut, our Site is hosted in the United States of America (‘USA’) and therefore is subject to applicable USA law (America the Great and that). So, any personal information provided by you us from somewhere else will be transferred and stored on our computers, servers and datacenters located in the USA, that its, outside your country. We are kidding, we don’t own a datacenter, we don't have the money for it. What we do is to use cloud services from USA companies, whose datacenters are located there.
In summary, if you access our Site from other countries, please know that you are transferring your personal information to us and, thus, our Site. Which is good, since USA privacy laws are second only to Canadian and European laws (wouldn’t it be “third to”?).
Notice to Californians
In fact, almost no one reads the Terms or the Policy, except for our larger clients and their attorneys.
Newsletters and Distribution Lists
Finally, we come to the meat outside the bone. Our distribution lists are sacred, and stored on a very secure server, almost magical-secure level. We will not ever sell them. You may download them from our systems at any time. We may also offer you to subscribe to our optional email newsletters! Our newsletters may not be as cool as yours but they are available to both public users and registered members.
You will know when you are subscribing, and you will also have the option to unsubscribe, either on your account settings or by following the unsubscribe links contained in the newsletter emails.
Under the CAN-SPAM Act, we will attempt to offer free opt-out mechanisms in every commercial request we sent to our users. Spam is bad, mmmkay.
Your rights! Who hooo!
Any user of our Site has the right to make a request to us in order to uphold his rights to:
- Access his personal data;
- Rectify his personal data when inaccurate or incomplete;
- Cancel his personal data;
- Object with legitimate reasons the process of his personal data; and/or
- Revoke his consent for the process of his personal data, at any moment.
These are called ARCO rights, and come from the EU Directive for personal data protection. Not even the good ol’ USA has these specific rights made into a law! Only California comes close.
Okay, now you know what this is about, so if you want to access, rectify or cancel your personal information in our possession, or otherwise revoke your consent to our use (please don’t! we will try better!), just send us an email with, at least, the following:
- Your name, address and e-mail address in order to notify you of the response to your request (silly to ask, but we sometimes receive emails with initials and no name!);
- Documents establishing your identity (like, you know, a valid driving license); and
- A clear and concise description of the personal over which you seek to enforce any of your ARCO rights (when rectification is requested, modifications to be made should be specified and documentation provided to back up its request).
- Really, tell us which info you talk about. Don’t send us an email with “delete that”.
You can send the email to: email@example.com. Once received, and after proper review (like an exam in school), we may edit, deactivate and/or delete your personal information from our databases.
You may also be able to edit the personal information we store about you, by going to your account settings in the Site (which will be easier in most cases).
Third party services
Like all good relationships, we'd like to know more about you. We may often collect and process analaytics data from your usage of our Site provided by a third party service.
Our Site may also include links to the websites of our commercial partners and other third parties. If you click and visit such websites, please consider that we are not responsible for the content, terms and policies used by such websites, and that our Policy and Terms do not apply anymore. You will be on your own! (but click on them anyway).
Cookies and beacons
The cookies we are talking about are small data files and identifiers that we put on your computer to allow us to recognize your browser and tell us how and which pages in our service you visit. Some cookies are temporary and others can be valid for several weeks or months (they are immortal!).
We also use web beacons, tags and other means on our Site. Such beacons are an electronic file, sometimes only a pixel or small image, embedded on websites. You can instruct your browser to refuse all cookies or to allow you to choose when to accept a cookie. If you do so, most websites you use will not work properly, by the way!
Rabbut may use Google AdSense and other third party software tools (such as remarketing codes) to gather information about the websites you browse, view or when you undertake specific actions in a website. Remarketing codes are used to follow you over the Internet (like a stalker!), such as when you view hotels of Paris on one site, and next you know, you see ads for hotels in Paris on another website. It’s like magic.
If you do not want to receive this type of advertising from us, now or in the future, you may opt-out by browsing Google’s opt-out page currently located at www.google.com/settings/ads/onweb. You can also use the Network Advertising Initiative website currently located at www.networkadvertising.org/choices and follow the instructions.
Fine, a lot to think about, but how can I contact you if I have a question?
If you have any questions or comments related to this Policy, or any further questions about our privacy practices and personal data procedures, please send us an email to: firstname.lastname@example.org.
Effective Date of this Policy is May 31, 2016.