ThankSwap (ThankSwap.org) feels strongly that your information and privacy rights must be protected.
We have created this statement to communicate our commitment to privacy and to ensure that you are comfortable with the measures taken to enhance your experience with us. We are dedicated to providing a safe, secure and enjoyable environment in which to read summaries of local and global news. This statement details our current information gathering procedures, which are subject to change without notice.
GDPR PRIVACY NOTICE
Last updated October 25, 2020
Thank you for choosing to be part of our community at ThankSwap (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you visit our websites ThankSwap.org (“Site”) and use our services, you trust us with your personal information. We take your privacy very seriously.
Table of contents
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- DO WE USE GOOGLE MAPS?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Summary: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, billing/payment information and social media profiles.
We collect personal information that you voluntarily provide to us when [registering at the Sites] expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as posting reviews in our directories or rating online businesses) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your email address which is necessary to use our services (e.g. receive a confirmation e-mail once your submission is approved, modified or rejected, you forget your password and you request a new one, you contact us for any issue related to our services), and any detail you provide to enhance your listing’s details page. You are fully responsible for the accuracy of the provided data.
Credentials. We collect passwords and similar security information used for authentication and account access. All personal data profiles are encrypted.
Payment Data. We collect limited billing information from our commercial customers utilizing our paid advertising services.
During the ThankSwap Submit service, we require information from the user on our order form. A user must provide contact information (such as name, email, and shipping address) and financial information (such as credit card number, expiration date). This information is used for billing purposes and to fill customer’s orders. If we have trouble processing an order, the information is used to contact the user.
All payments are handled by FlutterWave as well as Rave. Additionally, FlutterWave (https://www.flutterwave.com) and our merchant processing partners (Rave) send us a confirmation e-mail once a payment is completed.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
We store information that we collect through log files, and via the information provided during the ThankSwap Submit service, to create a profile of our users. A profile is stored information that we keep on individual users that details their characteristics. Consequently, collected information is tied to the users personally identifiable information to provide offers and improve the user experience. We DO NOT share your profile with other third parties.
Information automatically collected
In Summary: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our website.
We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. We use Google Analytics to help us understand how our customers use the Site; you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout;
HOW DO WE USE YOUR INFORMATION?
In Summary: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
- For special offers and updates: Established members will occasionally receive information on products, services, or special deals. Out of respect for the privacy of our users, we present the option to receive these types of communications. Please see the information listed below about Opt-out options.
- For service announcements – On rare occasions it is necessary to send out a strict service related announcement. For instance, if our service is temporarily suspended for scheduled maintenance we may send users and email alerting them of this event.
- For Customer Service – We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the user’s wishes.
- To Administer prize draws and competitions for our Business Purposes and/or with your Consent. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- To Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites.
- To enable user-to-user communications with your consent. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual.
- To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Summary: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
THIRD PARTY INTERMEDIARIES
We use an outside credit card processing company to bill users for services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.
In the event ThankSwap goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Web site for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.
Users who no longer wish to receive promotional communications may opt-out of receiving these communications by replying to email@example.com with “unsubscribe” in the subject line in the email.
Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights.
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants and Other Third-Party Service Providers.
We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.
a. payment processing, data analysis, email delivery, hosting services, customer service
b. marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
With your Consent. We may disclose your personal information for any other purpose with your consent.
Other Users. When you share personal information (for example, by posting reviews, ratings, contributions or other content to the Sites) or otherwise interact with public areas of the Site, such personal information may be viewed by all users and may be publicly distributed outside the Site in perpetuity.
Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
DO WE USE GOOGLE MAPS?
In Summary: Yes, we use Google Maps for the purpose of providing better service.
For a full list of what we use information for, please see the previous sections titled “Use of Your Information” and “Disclosure of Your Information.”
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Summary: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States of America. If you are accessing our Sites from outside the USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “Disclosure of Your Information” above), in other countries .
In particular ThankSwap complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, ThankSwap is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
ThankSwap is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework, ThankSwap is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Summary: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Summary: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. ThankSwap takes every precaution to protect our users’ information. When users submit sensitive information via the Web site, their information is protected both online and offline.
All pages and content on ThankSwap website are protected with SSL encryption (https). When our registration/order form asks users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – SSL.
While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information offline. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our financial department or a customer service representative) are granted access to personally identifiable information. Our employees are encouraged to use password-protected screen-savers when they leave their desk. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Our employees are reminded about the importance we place on privacy, and what they can do to ensure our users’ information is protected. Finally, the servers that store personally identifiable information are in a secure environment, behind a locked cage, in a locked facility.
If users have any questions about the security at our Web site, users can contact our Help Center.
However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information through the usage of SSL and encryption techniques, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Summary: We do not knowingly collect data from or market to children under 13 years of age.
We do not knowingly solicit data from or market to children under 13 years of age. By using the Site, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us at firstname.lastname@example.org
WHAT ARE YOUR PRIVACY RIGHTS?
In Summary: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below https://thankswap.org/contact-us. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
You may at any time review or change the information in your account or terminate your account by:
- Contacting us using the contact information provided below
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.
Opting out of email marketing:
If you have subscribed to our email newsletter for promotional marketing purposes, you can opt-out at any time by using the unsubscribe feature on any promotional correspondence or by contacting us at email@example.com. Please note that if you have an active listing service with ThankSwap, we may still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by contacting us using the contact information provided below.
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Summary: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 13 years of age, reside in California, and have a registered account with our Site, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
DO WE MAKE UPDATES TO THIS POLICY?
In Summary: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, email us at firstname.lastname@example.org or by postal mail to:
12 Iroka Street,
Off Verona Junction
Umudagu, Mbieri 461115
Imo State, Nigeria.