LAST UPDATED: June 4, 2020
iDeals group of companies includes iDeals Solutions Group Limited, iDeals Solutions Group, iDeals Solutions Operations Limited and their affiliates (“iDeals”, “we” or “us”) who are committed to respecting your data privacy and keeping your information secure and confidential.
EU-US PRIVACY SHIELD FRAMEWORK
- iDeals is subject to the investigatory and enforcement powers of the Federal Trade Commission;
- If we transfer your personal information to third parties, we will remain responsible and liable to you if the third party processes your personal information in violation of the Privacy Shield Principles, unless we prove we were not responsible for the event giving rise to the damage.
Personal Information provided by you: Product offered to visitors of the Site and users of the Application require you to register for a personal account with iDeals (“Personal Account”). When registering for a Personal Account, iDeals will ask you to supply us with certain information about yourself by filling out and submitting an online form. iDeals may ask you to voluntarily supply us with certain information about yourself by filling out and submitting an online form for marketing purposes as well.
To become a registered user you will have to create a Personal Account. Its creation implies providing the following information:
- Your name (first name and last name),
- Your company,
- Your title or work position,
- E-mail address,
- Home/work/mobile telephone number,
- Physical address (optional),
- 4 last digits of your credit/debit card number (optional),
- IP addresses and other information collected passively, as further detailed in the “Information that we obtain or collect automatically from your use of the Site” section below.
Information that we obtain or collect automatically from your use of the Site or Application: We may automatically collect certain information from your use of the Site or Application, such as usage data, preferences, or any other information concerning how you use the Product.
- Your browser type, language, plug-ins, Internet domain, type of device and operating system;
- Your Internet Protocol (IP) address;
- Your timezone;
- Your device screen resolution;
- The website(s) you visited before visiting the Site and the website(s) you visited after visiting the Site;
- Unique identifiers, including mobile device identification numbers, that may help detect the physical location of such devices;
- Data related to your interactions with content on the Site and Applications, such as use patterns and the type of content viewed or favorited in the Site and Applications.
In addition, by using our Site or Application, network information such as Product usage information, may be transmitted back to us. It helps us to determine how users are interacting with our Product, improve our Product, and correct any problems that may occur.
If you choose to use our referral service to invite a third party to use our Product, you represent that you have such third party consent to provide us with his/her Personal Information such as:
- E-mail address,
- Name (first name and last name),
- Title or work position,
- Home/work/mobile telephone number,
If you choose to use our additional service such as USB flash drive delivery for a third party, you may be requested to share the following information about this third party:
- home/work/mobile telephone number,
- Internet Protocol (IP) address,
- physical address.
In this case you represent that you have such third party consent to provide us with his/her Personal Information.
We collect your location based information such as country, region, city for the purpose of optimizing your connection to our data center. We will only share this information with our data center provider for the sole purpose of providing our service and Product to you.
As described above, we will ask you to create a Personal Account to enable you to use the Product. Once the Personal Account is created, you will be able to access, review and update your personal account information online via the Site or the Application.
Please note that you may choose not to create the Personal Account. If you choose so, you will still have access to many of the Site’s web pages, however, you may be unable to access certain options and services that we offer only to registered users.
USE OF PERSONAL INFORMATION
iDeals uses your Personal Information to:
- operate and improve the Site, Application, and Product;
- customize your experience on the Site, Application, and Product;
- deliver communications that may be of interest to you, either electronically or otherwise;
- enforce terms and conditions / user’s agreement;
- conduct market analysis, traffic flow analysis and related reporting to third parties;
- provide reports based on information collected from use of our Site, Application, and Product;
- keep you up to date on the latest Product announcements, software updates, software upgrades, system enhancements, special offers, and other information, provided that you can modify your marketing preferences;
- provide support and assistance with our Site, Application, and Product;
- verify user’s identity;
- provide you with shipping and billing information;
- request customer feedback;
- provide information related to the use of the Site, Application, and Product;
- conduct questionnaires and surveys in order to provide better products and services to our customers and end users. Your completion of any questionnaires is voluntary;
- understand more about you, so we can personalize newsletters and websites according to your preferences (e.g. enable you to request specific information on products and services to be included in these newsletters);
- marketing purposes;
- for any other purposes disclosed to you at the time we collect your Personal Information.
PROCESSING AND SHARING YOUR PERSONAL INFORMATION
By accessing or using the Site, Application, or Product, or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have privacy laws different from your country of residence. Please note that some of the recipients of your Personal Information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your Personal Information that comply with our legal obligations. If the recipient is not a member of the iDeals group of companies, the adequate safeguard might be provided by signing a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
We may also share Personal Information with third parties including as follows:
Vendors, Consultants and Other Service Providers: We may share your Personal Information with third-party vendors, consultants and other service providers who are working on our behalf and require access to your Personal Information to carry out their work, such as to process billing, provide customer support, etc. These service providers are authorized to use your Personal Information only as necessary to provide services to iDeals or Product.
In some cases, we may share your information with third-party vendors to understand which areas and features of the Product are most popular and/or to improve the overall effectiveness of Product and its features.
- Corporate Account: If you are an individual registered user and the domain of the primary email address associated with your corporate account is owned by your employer and was assigned to you as an employee of that organization, and such organization wishes to establish a corporate account, then certain information concerning past use of your individual account may become accessible to that organization’s administrator including your email address.
- For Collaboration: We may share your Personal Information when you choose to use collaboration features in the Product that by their nature support sharing with third parties who you choose. Your name, email address, information from your profile and online account, and any сontent you choose to distribute will be shared with such third parties. Such third parties may communicate with you by posting comments or emailing you in connection with your use of the collaboration features of the Product. For example, third parties who you invite to collaborate with you using the collaboration features of the Product may also modify сontent that you have shared, upload documents to сontent you have shared, share such сontent outside of the Product, and provide other third parties with the rights to view the сontent you have shared.
- Compliance with Laws: We may disclose your Personal Information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms and conditions / user’s agreement, (c) to protect the security or integrity of the Product, (d) to protect iDeals, our customers or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
- Aggregated or Anonymized Data: We may also share aggregated or anonymized information with third parties that does not directly identify you.
COLLABORATION AND SHARING FEATURES
iDeals offers collaboration features or other integrated tools, which allow you to share your сontent through the Product. Because these features are of the collaborative nature of the Product and are based on the permissions and settings you choose, their use enables you to share сontent with people you want to collaborate with. You can choose to change your settings at any time for a file or folder through your account.
SECURITY OF INFORMATION
Personal Information you provide to us is protected by the password you create when registering to use the Site, Application, and Product. Please understand that you can help prevent the unauthorized disclosure of information by choosing and protecting your password appropriately. You can also help prevent unauthorized disclosure by not sharing your password and preventing others from using your computer or mobile device.
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:
- SSL encryption (https) everywhere where we deal with Personal Information.
- Databases encryption;
- Hosting data on physically secure servers that are also protected by firewalls.
We use commercially reasonable security procedures to protect all collected Personal Information. Please understand that no security system is perfect and, as such, we do not guarantee the security of the Site, or that your Personal Information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, then we may either post a notice, or attempt to notify you by email,. We will take reasonable steps to remedy the breach.
DATA SUBJECT RIGHTS
You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests. We may ask you to provide us with additional information in connection with your request. If we need to verify your identity or the nature of your request, we may ask you to provide more details regarding your Personal Information. In such situations, however, we will still respond to let you know of our decision.
- Access: You can request to receive a copy of the Personal Information we hold about you.
- Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement it. You can also correct some of this information directly from your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to inform that you object to the collection or use of your Personal Information for certain purposes.
- Erasure: You can request that we erase some or all of your Personal Information from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
- Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of such data collection), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have then to provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Products.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our affiliates and/or third parties for marketing purposes) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its customers, iDeals acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA using the information set forth in the “Contact Us” section below.
Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.
ACCESS BY MINORS
RECOURSE, ENFORCEMENT AND LIABILITY
If the Personal Information in question was transferred from the EU or Switzerland to the United States, and you are not satisfied with our response, we have further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association (AAA)’s Independent Conflict Dispute Resolution ICDR/AAA Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.adr.org/Support for more information or to file a complaint.
Additionally, with respect to complaints concerning Personal Information that is transferred from the EU, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. iDeals will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning Personal Information that is transferred from the EU to the United States brought under Privacy Shield.
For complaints concerning Personal Information that is transferred from Switzerland, we commit to cooperate with Swiss Federal Data Protection and Information Commissioner (“FDPIC”) and comply with the advice given by the FDPIC. Complaints regarding handling of personal data pertaining to EU and Swiss citizens may be reported by the individual to the relevant Data Protection Authority.
The resource mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.
If you have any inquiries or complaints, you may contact us:
by email: email@example.com.
in writing: Albert Buildings, 49 Queen Victoria Street, London EC4N 4SA, the United Kingdom; The Hub, Suite E303, Triq Sant Andrija, San Gwann, SGN1612, Malta or 815 N Royal Street, Suite 202, Alexandria, VA 22314.