: [July 4th, 2020]
This Privacy Statement explains how THREEIN (collectively, "THREEIN," "we," "us," or "our")
collect, use, share and process your information.
1.1 Collection and Use of Personal Data
Personal data is information that can be used to directly or indirectly identify
you. Personal data also includes anonymous data that is linked to information
that can be used to directly or indirectly identify you. Personal data does not
include data that has been irreversibly anonymized or aggregated so that it
can no longer enable us, whether in combination with other information or
otherwise, to identify you.
Here is a description of the types of personal data we may collect and
how we may use it:
1.1.1 What Personal Data We Collect
Depending on the products and services you use, we collect different kinds of
personal data from or about you.
Data you provide:
We collect the personal data you provide when you use our
products and services or otherwise interact with us, such as when you create
an account, Contact Us, participate in an online survey, use our online help or
online chat tool.
Data about payments:
If you make a purchase, we collect personal data in connection with the purchase. This data includes your payment data, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing, shipping, and contact details.
Data about use of our services and products:
When you visit our websites, we may collect data about the type of device you use, your device's unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, and location information from or about the computers, phones, or other devices on which you install or access our products or services. Where available, our services may use GPS, your IP address, and other technologies to determine a device's approximate location to allow us to improve our products and services.
1.1.2 How We Use Your Personal Data
Generally speaking, we use personal data to provide, improve, and develop our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our customers.
THREEIN processes and determines how to process your personal data as data controller for the following purposes:
1.2 Cookies and Similar Technologies
You can remove or reject cookies using your browser or device settings, but in some cases doing so may affect your ability to use our products and services.
Please read our
1.3 Disclosure of Personal Data
We make certain personal data available to strategic partners that work with us to provide our products and services or help us market to customers. Personal data will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.
1.3.1 Service Providers
We share personal data with companies that provide services on our behalf, such as website hosting, email services, marketing, sponsoring of sweepstakes, contests, and other promotions, auditing, fulfilling customer orders, data analytics, providing customer service, and conducting customer research and satisfaction surveys. These companies are obligated to protect your data and may be located wherever we operate.
1.3.2 Corporate Affiliates and Corporate Business Transactions
We may share personal data with all THREEIN affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
1.3.3 Legal Compliance and Security
It may be necessary—by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence—for us to disclose personal data. We may also disclose personal data if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
1.3.4 Legal Basis For The Processing of Personal Data from EEA Residents
It may be necessary—by law, legal process, litigation, and/or requests
from public and governmental authorities within or outside your country
of residence—for us to disclose personal data. We may also disclose personal
data if we determine that for purposes of national security, law enforcement,
or other issues of public importance, disclosure is necessary or appropriate.
1.4 Your Rights
We take reasonable steps to ensure that your personal data is accurate, complete, and up to date. You have the right to access, correct, or delete the personal data that we collect. You are also entitled to restrict or object, at any time, to the further processing of your personal data. You have the right to receive your personal data in a structured and standard format. You may lodge a complaint with the competent data protection authority regarding the processing of your personal data.
To protect the privacy and the security of your personal data, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data that we maintain.
to exercise your rights. We will respond to your request in a reasonable timeframe, and in any event in less than 30 days.
1.5 Closing Accounts
to close your account in relation to the following uses of your personal
providing, improving, and developing our products and services;
communicating with you;
sharing your personal data with third party partners for marketing communications;
offering and measuring targeted advertisements and services; or
promoting safety and security.
to close your account in relation to the use of your personal data for the provision of products and services you requested.
If you close your account, we have no obligation to retain your data, and we may delete any or all of your data without liability. However, we may retain data related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate purposes, such as analysis of non-personal data, account recovery, auditing our records, and enforcing our rights and obligations under our agreements.
1.6 Third-Party Websites and Services
Our websites, products, and services may contain links to or the ability for you to access third-party websites, products, and services. We are not responsible for the privacy practices employed by those third parties, nor are we responsible for the information or content their products and services contain. This Privacy Statement applies solely to data collected by us through our products and services. We encourage you to read the privacy policies of any third party before proceeding to use their websites, products, or services.
1.7 Data Security, Integrity, and Retention
We use reasonable technical, administrative, and physical security measures designed to safeguard and help prevent unauthorized access to your data, and to correctly use the data we collect. For example, access to your personal data is restricted to our employees, contractors, and agents who need access to such data to perform their assigned job duties.
It is important that you take precautions to protect against unauthorized access to your THREEIN products, account credentials, and computer or other devices. If you feel that the security of your account or personal data has been compromised, please immediately
. Please be aware that, despite our best efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.
We will retain your personal data for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.
Our products and services are intended for adults. Accordingly, we do not knowingly collect, use, or disclose data from children under 16. If we learn that we have collected the personal data of a child under 16, or the equivalent minimum age depending on the jurisdiction, we will take steps to delete the data as soon as possible. Please immediately
if you become aware that a child under 16 has provided us with personal data.
1.9 Data Transfers, Storage, and Processing Globally
When we share your personal data with our partners, THREEIN affiliated companies, and service providers, your personal data may be transferred to and/or made accessible worldwide. In such circumstances, we will enter into model contractual clauses, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our partners or service providers have adopted such internal policies.
1.10 Changes to this Privacy Statement
We may periodically change this Privacy Statement to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. We expect most such changes to be minor. Any non-material changes will take effect immediately upon posting of an updated Privacy Statement.
However, there may be cases where changes to the Privacy Statement may be more significant. In such cases, we will first provide a more prominent notice.
Your continued use of the our products and services after the effective date of the Privacy Statement means that you accept the revised Privacy Statement. If you do not agree to the revised Privacy Statement, please refrain from using our products or services and
to close any account you may have created.
1.11 Contact Us
If you have any questions regarding this Privacy Statement or its implementation, here is how you can reach us:
In relation to the use of your personal data for the following purposes:
Providing, improving, and developing our products and services;
Communicating with you;
Sharing your personal data with third party partners for marketing communications;
Offering and measuring targeted advertisements and services;
Promoting safety and security.
In relation to the use of your personal data for the provision of products
and services you requested: