Effective Date: August 27, 2020
1. Whom this notice applies to
The Privacy Notice was last changed on August 27, 2020.
If you have any questions about the Privacy Notice, please email us at: firstname.lastname@example.org
2. Why we collect the information
We collect, store, and use your Personal Information to allow, facilitate, and improve access to the Website, the Apps and the Services, and for the purposes set out in more detail in section 4.
3. Legal requirements
We are required to collect parts of the information in order to comply with certain legal obligations, including, but not limited to, anti-fraud and know your customer (“KYC”) laws. If such information is not provided, we cannot agree to provide a product or service for you.
We may also collect the information and disclose it to law enforcement bodies or regulatory authorities upon reasonable request thereby, or pursuant to defending a legal claim.
We will retain information related to an investigation or a dispute until the issue is resolved.
4. What information we collect and how we use it
(a) We may collect the following information from users:
- IP address;
- device information (e.g. operating system, device identifiers, and mobile network system);
- Website usage data, such as webpages viewed, viewing time, click information, and other analytical data;
- error logging, event recording, and user experience data;
- hardware and browser settings;
- requests made;
- time and date of requests;
- the pages visited and search terms used;
- location information;
- email address;
- your full name;
- billing address;
- shipping address;
- date of birth;
- any Personal Information posted on our social media accounts;
- whether our emails were received and whether hyperlinks therein were accessed;
- marketing preferences; and
- any other Personal Information that you choose to submit to us.
We may also collect Personal Information about you from other sources. We obtain this information from sources such as:
- our business partners;
- third-party service providers, such as Google AdSense;
- other users of the Services;
- banking or other financial services providers; and
- publicly available sources
4(b) We may use the information to:
- deliver our Services to you;
- register your account on the Services;
- verify and authenticate your account information;
- supply you with requested goods, products, or services, including the use of our online store;
- send you informational, administrative, or promotional communications;
- alter and develop new services based on: the information collected, user behavior, and users’ technical capabilities;
- improve the Services to better suit the behaviors and technical capabilities of the users;
- identify issues with the Website, the Apps and/or the Services;
- monitor the way the Website and the Apps are used (including, but not limited to, access points, access methods, and peak usage times);
- enter into, administer and complete any and all contracts we enter into with users;
- verify compliance with our Terms of Service;
- conduct investigations;
- respond to inquiries and provide you with customer support;
- increase the security and safety of our Services and users;
- perform analytics on our Services;
- make the advertising we show you on the Website and the Apps more relevant and interesting to you (using third-party tools, including programmatic advertising, retargeting, cookies, web beacons and similar technologies to collect information about your browsing behavior);
- serve any other purposes that are disclosed to you and to which you consent; and
- serve any purpose required by law.
4(c) Our collection and use of your information aids our legitimate interests in managing our business and the website. Our legitimate interests include, but are not limited to:
- tracking traffic to the Website to ensure the future viability of our business and the Website;
- understanding how users use the Website and the Apps;
- understanding which services users value;
- improving the functionality and content of the Website and the Apps;
- ensuring the website and our network are safe and secure; and
- preventing fraud.
4(d) How we collect information through technological means
When you use the Services, we may collect information that is automatically sent to us by your web browser. This information may include your domain name and your numerical IP address. We may also collect other information, such as the type of browser you use, which pages you view and the files you request. We may also collect software and debug information, information from API access tokens, and referral website addresses through Apache webserver stats.
We use this information to improve our understanding of how users use our Services, to improve our Services, and attract more users. We may also use the information collected for our own research and development purposes.
The amount of information that is sent to us by technological means depends on your browser or device and settings you use. Please refer to the instructions provided by your browser or device if you want to learn more about what information it sends to Services you use, or how you may change or restrict this.
- to improve functionality and performance of our Services, including tailoring our Services to increase relevancy of content displayed to you;
- to facilitate your transactions on the Services;
- to authenticate users of our Services;
- to provide us with insights on how users use our Services and other analytics, such as traffic on our Services;
- to rex your settings and preferences; and
- to deliver relevant advertisements to you based on your interests, preferences, and activities. Cookies also help to avoid delivering the same advertisements to you too many times and to measure the usefulness of advertisements you have been delivered. Information gathered by Cookies may be shared with third parties, including advertisers. This means that sometimes you’ll see our Services advertised elsewhere on the internet.
Please be aware that if you disable or remove Cookies some parts of our Services will not work and that when you revisit our Services your ability to limit cookies is subject to your browser settings and limitations. You can also find out more information about managing, disabling, and deleting cookies at www.allaboutcookies.org.
5. How long we retain the information
We retain the information as long as it is reasonably necessary, this includes, but is not limited to, retaining the information until we have complied with all legal, accounting, and reporting requirements.
6. What information we share
There are certain circumstances in which we transfer the information, or parts thereof, to employees, contractors, service providers, and/or other third parties (collectively, the “third parties”). These third parties may process your personal data for us, and the parts of the information we provide to the third parties will only pertain to the function of each third party.
We reserve the right to transfer Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We may also disclose your Personal Information for any other purpose permitted by law or to which you consent.
We may disclose your Personal Information in the good faith belief that such action is necessary to:
- protect and defend our rights or property;
- prevent or investigate possible wrongdoing in connection with our products or services;
- protect the personal safety of our customers or the public; or
- protect against legal liability.
7. Where the information is stored
In some cases, your information, including Personal Information, may be transferred to — and maintained and processed on — computers located outside of the Republic of Panama. Therefore, your Personal Information may be available to government authorities under lawful orders and laws applicable in those foreign jurisdictions.
8. What rights you have
You have certain rights in relation to the information, described in more detail below. Some of these rights will only apply in certain circumstances.
- Request: you are entitled to ask us if we are collecting and processing your information.
- Access: If we are processing your information, you may request access to your information, and receive a copy of the information pertaining to you.
- Correction: you may request that any inaccurate information about you is corrected.
- Erasure: you may request that we delete or remove your information, but we may refuse such requests if, for example, the personal data is required for compliance with any legal obligation or is connected to any claims.
- Transfer: you may request the transfer of your information to another party.
- Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims.
- You may also object to collection of your personal information for direct marketing purposes.
9. Our direct marketing practices
We may use the information you give us on the website for direct marketing purposes to provide communications of interest to you. We will only do this with your consent (where required by law).
You can opt-out of receiving directing marketing from us at any time. You can do this by contacting us at email@example.com.
10. Our use of third-party tools
We use third-party tools to personalize what is displayed to you on the Website and through the Apps.
We use third-party tools, including programmatic advertising and retargeting, to make the content of the website more relevant and interesting to you.
11. Our security measures
In order to protect your information, we have implemented physical and technical safeguards to prevent unauthorized access to the information.
12. Links to third-party websites
The Website, the Apps and our communications with you may contain links to third-party websites.
Such third-party websites may have their own privacy notices, detailing their own obligations and practices with respect to the collection, retention, and treatment of personal data.
13. Children may not submit personal information
OUR PRODUCTS AND SERVICES ARE NOT INTENDED FOR INDVIDUALS UNDER 18 OR THE AGE OF MAJORITY, WHICHEVER IS OLDER. IF YOU ARE UNDER THIS AGE, YOU MUST NOT ACCESS OR USE OUR PRODUCTS OR SERVICES AT ANY TIME OR IN ANY MANNER.
We do not knowingly collect any information from any persons under the age of 18. If you are under the age of 18, you may not submit any personal information to us.
If you have reason to believe that we are in receipt of personal information pertaining to a person under the age of 18, contact us at firstname.lastname@example.org.
14. Privacy Contacts
Privacy Officer Address:
PH Torre Banco Panama – Peso 15
Blvd. Costa del Este y Ave. La Rotonda
Costa del Este, Apartado 0832-00429
Panama City, Panama