YepClick S.R.L (we, our and us) operates the website.
YepClick S.R.L is a company based in Costa Rica, our registered address is YepClick S.R.L, 300m sur de Duende Gourmet, Puerto Viejo, Limón, 41001, Costa Rica.
Our email address is email@example.com.
INFORMATION WE COLLECT WHEN YOU CONTACT US:
We collect and use information from individuals who contact us in accordance with this section.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email.
When you contact us using our contact form, we collect name, email address, and IP address. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
INFORMATION WE COLLECT WHEN YOU INTERACT WITH OUR WEBSITE:
We collect and use information from individuals who interact with particular features of our website in accordance with this section.
When you sign up for our e-newsletter on our website or opt to receive news, offers from us by entering the name and email address and clicking subscribe or ticking a box at checkout indicating that you would like to receive your e-newsletter, we collect your email address.
INFORMATION COLLECTED WHEN YOU PLACE AN ORDER:
When you place an order for services on our website, we collect your name, email address, company address, and any other mandatory information that will be submitted using the sign up form.
If you do not provide this information, you will not be able to purchase services from us on our website or enter into a contract with us.
Processing your payment:
After you place an order on our website you will need to make payment for the services you have ordered. In order to process your payment we use a third party payment processor, your payment will be processed by the third party payment processor you choose to process your payment.
INFORMATION COLLECTED OR OBTAINED FROM THIRD PARTIES:
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties:
Generally, we do receive information about you from third parties. The third parties from which we receive information about you will generally include Apple and Google.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
WHERE WE RECEIVE INFORMATION ABOUT YOU IN ERROR:
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties:
In certain circumstances we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as online customer databases, business directories, social media, and websites.
DISCLOSURE AND ADDITIONAL USES OF YOUR INFORMATION:
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers:
We use third parties to provide us with services and data which are necessary to run our business or to assist us with running our business.
Your information will be shared with the service providers where necessary to provide you with the service you have requested, whether that is accessing our website, or ordering services from us.
Disclosure of Your Information to Other Third Parties:
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. and Apple: Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/.
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout.
TRANSFER AND STORAGE OF YOUR INFORMATION:
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors.
DISCLOSURE AND USE OF YOUR INFORMATION FOR LEGAL REASONS:
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties.
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
We will use and process your information in order to comply with legal obligations to which we are subject.
HOW LONG WE RETAIN YOUR INFORMATION:
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Server log information: we retain information on our server logs for one year.
Order information: when you place an order for services, we retain that information for six years following the end of the financial year in which you place your order, in accordance with our legal obligation to keep records for tax purposes.
CRITERIA FOR DETERMINING RETENTION PERIODS:
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
· The purpose and use of your information both now and in the future such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future;
· Whether we have any legal obligation to continue to process your information;
· Whether we have any legal basis to continue to process your information;
· Analyzing mobile ad fraud;
· How valuable your information is;
· any relevant agreed industry practices on how long information should be retained;
· the levels of risk, cost and liability involved with us continuing to hold the information;
· how hard it is to ensure that the information can be kept up to date and accurate; and
· Any relevant surrounding circumstances.
HOW WE SECURE YOUR INFORMATION:
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
· Only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
· Using secure servers to store your information;
· Verifying the identity of any individual who requests access to information prior to granting them access to information;
TRANSMISSION OF INFORMATION TO US BY EMAIL:
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet, you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
YOUR RIGHTS IN RELATION TO YOUR INFORMATION:
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to firstname.lastname@example.org:
· To request access to your information and information related to our use and processing of your information;
· To request the correction or deletion of your information;
· To request that we restrict our use of your information;
· To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller;
· To object to the processing of your information for certain purposes; and
· To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
· The right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
FURTHER INFORMATION ON YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA AS AN INDIVIDUAL:
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
· https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
HOW WE VERIFY YOUR IDENTITY:
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION FOR CERTAIN PURPOSES:
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to email@example.com:
· To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ based on any of these purposes; and
· To object to us using or processing your information for direct marketing purposes.
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
· Clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
· Sending an email to firstname.lastname@example.org, asking that we stop sending you marketing communications.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 16, please do so by sending an email to email@example.com.
Address: YepClick S.R.L, 300m sur de Duende Gourmet Puerto Viejo, Limón, 41001, Costa Rica.
© All rights reserved. 1st of November, 2018.