Purpose

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected;
4. The rights of Site users;
5. The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent

By using our Site users agree that they consent to:

The conditions set out in this Privacy Policy, including the collection, use, and sharing of data as described herein.

When the legal basis for us processing your personal data is that you have provided your consent to that processing (for example, where required by law for specific activities like non-essential cookies or certain data sharing), you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: Contacting us via the methods listed in the Contact Information section, or adjusting your settings where applicable (e.g., cookie preferences).

Legal Basis for Processing

We collect and process personal data about users only when we have a legal basis for doing so. For users in the EU, this is under Article 6 of the GDPR. Depending on the specific processing activity, our legal basis may include:

1. Users have provided their consent to the processing of their data for one or more specific purposes (e.g., marketing emails, certain types of data sharing for advertising measurement where required).
2. Processing is necessary for the performance of a contract to which the user is party (e.g., processing payment information for a purchase).
3. Processing is necessary for compliance with a legal obligation.
4. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the user which require protection of personal data (e.g., basic website analytics, security measures).

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

1. IP address;
2. Location (general, based on IP address);
3. Clicked links and navigation patterns;
4. Content viewed;
5. Information collected via cookies and similar technologies (see Cookie Policy below).

Use of Google Analytics:

Our website employs Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States for the purpose of evaluating website activity and compiling reports for us.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site (e.g., filling out forms, making purchases, contacting us):

1. Name;
2. Age;
3. Sex;
4. Email address;
5. Address;
6. Payment information;
7. Educational background;
8. Any other information you voluntarily provide.

This data may be collected using the following methods:

1. Forms submitted by users;
2. Account registration;
3. Transaction processes.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy without appropriate notice or consent where required.

The data we collect automatically is used for the following purposes:

1. Website analytics and statistics to understand usage patterns and improve site functionality;
2. Basic website operation and security;
3. Personalizing user experience based on preferences (where applicable cookies are accepted);
4. Assisting with advertising measurement and effectiveness analysis (see below).

The data we collect when the user performs certain functions (non-automatic data) may be used for the following purposes:

1. To provide the services requested (e.g., process transactions, manage orders, create accounts);
2. Communication regarding your account, transactions, or inquiries;
3. To send you promotional emails and newsletters about our services, new features, and special offers, if you have opted-in or where otherwise permitted by law. You can opt-out at any time;
4. Verification purposes;
5. Internal record keeping.

Advertising Measurement and Conversion Tracking:

To understand the effectiveness of our advertising campaigns and measure conversions, we may share certain information with third-party advertising partners, such as Google. This information might include data collected automatically (like cookie identifiers or IP addresses indicating an interaction with an ad) and data you provide (like your email address or phone number, typically shared in a secure, hashed format that does not directly reveal your identity to the partner). This sharing helps us and our partners attribute actions taken on our Site (like form submissions or purchases) back to specific advertisements and optimize future advertising efforts. Where required by law (e.g., in the EU/UK), this sharing for advertising measurement purposes will only occur if you have provided explicit consent.

Your Choices and Rights

You have the right to opt-out of receiving promotional communications from us. You can do this by following the unsubscribe instructions included in the promotional emails or by contacting our support team. Please note that even if you opt-out of receiving promotional communications, we may still send you non-promotional emails, such as those about your account or ongoing business relations.

You also have rights regarding your personal data as outlined in the "Your Rights as a User" section below, including the right to object to certain processing activities.

Sharing of Data

We handle your data with care and limit sharing as follows:

1. Employees: Access to user data is granted to our employees on a need-to-know basis to perform their job functions in accordance with this Privacy Policy.
2. Service Providers: We may share data with third-party service providers who perform functions on our behalf (e.g., payment processors, email service providers, hosting providers). These providers are contractually obligated to protect your data and use it only for the services they provide to us.
3. Advertising Partners for Measurement: As described in the "How We Use Personal Data" section, we may share specific, potentially hashed, data with advertising partners like Google solely for the purpose of measuring advertising effectiveness and conversion attribution, subject to legal requirements and your consent where applicable.
4. Legal Requirements: We may disclose your data if required by law, subpoena, or other legal process, or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) enforce our agreements with you; (c) investigate and defend ourselves against any third-party claims or allegations; (d) protect the security or integrity of our Service; or (e) exercise or protect the rights and safety of our company, our users, personnel, or others.
5. Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Site of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.

Anonymized and Aggregated Data Sharing

We may share anonymized or aggregated data (information that does not personally identify you) with third parties for various purposes, including research, reporting, and improving our services or marketing analysis.

Third-Party Sites and Services

Our Site may contain links to external websites or integrate with third-party services. We do not control these external sites or services and are not responsible for their privacy practices. We encourage you to read their privacy policies.

How Long We Store Personal Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as necessary to resolve disputes or enforce our agreements. The specific retention period depends on the nature of the data and the purpose for which it is processed.

You will be notified if your data needs to be kept for significantly longer than initially anticipated for a specific purpose.

How We Protect Your Personal Data

We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. This includes using encryption (like SSL/TLS for data transmission), access controls, and secure server facilities.

While we take all reasonable precautions to ensure that user data is secure, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security beyond what is reasonably practical.

Your Rights as a User

Depending on your location and applicable law (particularly under GDPR for EU/UK residents), you may have the following rights regarding your personal data:

1. Right to be informed: To know how your data is being collected and used.
2. Right of access: To request a copy of the personal data we hold about you.
3. Right to rectification: To request correction of inaccurate or incomplete data.
4. Right to erasure ('right to be forgotten'): To request deletion of your data under certain conditions.
5. Right to restrict processing: To request limitation of how we use your data under certain conditions.
6. Right to data portability: To receive your data in a portable format or have it transferred directly to another controller under certain conditions.
7. Right to object: To object to processing based on legitimate interests or for direct marketing purposes.
8. Rights related to automated decision-making and profiling: To not be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you, under certain conditions.

Residents of other jurisdictions (e.g., California) may have similar or additional rights under their local laws (e.g., right to know, delete, opt-out of sale/sharing).

Children

Our Site and services are not directed to children under the age of 16 (or a higher age threshold where applicable by local law). We do not knowingly collect personal data from children under this age. If we learn that we have collected personal data from a child under the relevant age threshold, we will take steps to delete the information as soon as possible. If you believe we might have any information from or about a child under this age, please contact us.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to exercise any of your rights regarding your personal data (as described above), or have questions about how we handle your data, please contact us using the details provided in the "Contact Information" section below.

[email protected]

Do Not Track Notice

Some web browsers offer a "Do Not Track" ("DNT") signal. Currently, there is no industry standard for how websites should respond to DNT signals. Therefore, like many websites, we do not currently alter our practices when we receive a DNT signal from a user's browser.

How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the "How to Access, Modify, Delete, or Challenge the Data Collected" section and your rights outlined above, we provide the following specific opt-out methods:

1. Marketing Emails: You can opt-out of receiving marketing emails from us by clicking the "unsubscribe" link provided at the bottom of any marketing email you receive.
2. Cookie Preferences: You can typically manage your cookie preferences through your browser settings or through a cookie consent management tool if provided on our Site. Disabling certain cookies may affect the functionality of the Site.
3. Advertising Measurement Opt-Out: You may be able to opt-out of certain interest-based advertising and data sharing for measurement through industry opt-out programs (like the NAI or DAA websites) or through the settings provided by advertising platforms like Google (e.g., Google Ad Settings).

Cookie Policy

A cookie is a small file stored on your device (computer, phone, tablet) by a website. Its purpose is to remember information about you, such as login details, language preference, or browsing habits. You can usually configure your browser to notify you when cookies are being sent or to disable cookies entirely, but doing so may impact your experience on our Site.

We use the following types of cookies on our Site:

1. Strictly Necessary Cookies

These cookies are essential for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

2. Functional Cookies

These cookies are used to remember choices you make on our Site to provide enhanced functionality and a more personalized experience. For example, they can remember your preferred language settings for your next visit. If you do not allow these cookies, some personalization features, like remembering your language preference, may not function properly.

3. Performance / Analytical Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site (e.g., using Google Analytics). They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance effectively.

4. Targeting / Advertising Cookies

These cookies may be set through our site by us or our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They may also be used to measure the effectiveness of advertising campaigns by linking actions you take on our site back to ads you may have seen (conversion tracking). They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising, and advertising measurement based on your activity may be less accurate. Consent is typically required for these cookies, especially in regions like the EU/UK.

Modifications

This Privacy Policy may be amended from time to time to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top or bottom of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If the changes are significant, we may provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

Complaints

If you have any concerns or complaints about how we process your personal data, please contact us first using the methods provided in the 'Contact Information' section. We are committed to working with you to resolve any concerns.

If you feel that your concerns have not been addressed satisfactorily, you may have the right to lodge a complaint with a relevant data protection supervisory authority in your jurisdiction (e.g., your local authority in the EU/UK, the FTC or your state's Attorney General in the US).

Contact Information

If you have any questions, concerns or complaints regarding this Privacy Policy or our data practices, you can contact us at:

[email protected]

Effective Date: April 27, 2025