EU, UK, and Swiss Residents
ADDITIONAL INFORMATION FOR EU, UK, AND SWISS RESIDENTS
This section provides details we are required to provide to you under the General Data Protection Regulation (the “GDPR”, deemed for purposes of this notice to include the UK Data Protection Act of 2018 and the Swiss Federal Act on Data Protection (“FADP”)). This section applies solely to residents of the United Kingdom (“UK”) and, the European Economic Area (“EEA”), and Switzerland as information about people who live outside these areas may not be handled in the manner described in this section.
1. PERSONAL DATA
In this section, the term “personal data” has the meaning set forth in the GDPR: information relating to an individual that could directly or indirectly identify the individual.
As explained in the Policy above, we may create De-identified Data and disclose it to our Subscribers. De-identified Data does not directly identify you, and we apply measures to the data so that it is very unlikely that it could be used to indirectly identify you. However, under the GDPR, De-identified Data is still considered to be personal data under the GDPR. Accordingly, this section provides required disclosures under that law.
2. PERSONAL DATA COLLECTION, PROCESSING, DISCLOSURE, AND RETENTION
The Policy above describes the personal data we collect about you, the purposes for which we use personal data, the entities and parties to whom we may disclose personal data, and how long we retain personal data.
We process personal data where we have a legal basis to do so. Our legal bases for processing your personal data as described in the Policy above include (depending on the personal data and the circumstances of processing):
To perform our obligations under a contract or commitment to you (for example, to provide the Services you have requested of us or to comply with our Terms).
To further our legitimate interests (for example, to ensure the security of our Services, operate our business and the Services, defend our legal rights, and prevent fraud).
To comply with applicable legal obligations (for example, to respond to a subpoena).
For any purpose to which you have consented (for example, purposes to which you consent during the sign-up flow).
3. YOUR RIGHTS
The GDPR (deemed for purposes of this notice to include the UK Data Protection Act of 2018 and the Swiss Federal Act on Data Protection (“FADP”)) provides EEA, and UK, and Swiss residents with the following rights:
The Right to Access: You have the right to request we provide access to and/or a copy of the personal data we process about you, confirmation of whether we process personal data about you, and certain information about such personal data and/or our processing of it.
The Right to Correct: You have the right to request we correct inaccurate personal data about you.
The Right to Delete: You have the right to request we delete personal data about you if certain conditions are met.
The Right to Restrict Processing: You have the right to request we restrict our processing of personal data about you if you contest the accuracy of the personal data, the processing is unlawful, we only need the personal data to exercise and defend our legal rights, or you have exercised the right to object.
The Right to Object: You have the right to object to our processing of personal data about you based on legitimate interest or tasks carried out in the public interest.
The Right to Data Portability: You have the right to request we provide you with personal data about you in a structured, commonly used, machine-readable format, in certain situations and subject to technological limitations.
The Right to Withdraw Consent: When our processing of personal data about you is based on you consent, you have the right to withdraw consent to the processing. This does not affect our processing of personal data collected prior to your withdrawal of consent.
The Right Not to be Subject to Automated Decision-Making: You have the right not to be subject to decisions by us that produce legal effects (or similarly significant effects) for you, and that are based solely on automated processing.
The Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. However, we encourage you to contact us first, and we will do our best to resolve your concern.
To exercise any of these rights (except the right to lodge a complaint), please complete our privacy request form.
4. CROSS-BORDER TRANSFERS
As mentioned in the policy above, we are located in the United States, and we collect, process, transfer to, and store your personal data in the United States. By using our Services, you acknowledge and consent to us transferring information collected through the Services in this way.
Where required, we will use appropriate safeguards for transferring data outside of the UK, and/or EEA, and/or Switzerland. This includes signing Standard Contractual Clauses that govern the transfers of such data. For more information about these transfer mechanisms, please contact us using one of the methods in the “Contact Us” section of the Policy above.
