Effective Date: June 26, 2018
Clear Coast Ltd. ("Greetings Island", "we", "our" or "us") offers high quality templates and online design tools that allow our users to customize and produce attractive invitations, greeting cards and e-cards (the "Platform"), available through our website www.GreetingsIsland.com (the "Site") and the Greetings Island mobile application (the "App", and together with the Site and Platform – the "Services").
We are strongly committed to making our Privacy practices more transparent and fair. This Privacy Notice describes how we collect, store, use and disclose personal data regarding individuals who visit our Site or use our Platform ("Users" or "you"), and how we process personal data you provide concerning your contacts and recipients ("Recipients"), and our role as "Data Processor" of such data. It applies whenever you visit our Services or use our Platform, interact with us or otherwise access or use any of our Services.
Specifically, it describes our practices regarding –
- Data Collection
- Data Uses
- Cookies, Tracking and Advertising Uses
- Storage and Retention
- Data Sharing
- Data Security
- Data Subject Rights
- Data Controller/Processor & Recipients Data
- Updates & How to contact us
We strongly urge you to read this notice and make sure that you fully understand and agree to it. If you do not agree to this notice, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services (for instance, you may still use parts of our Platform without signing up, but you will not be able to enjoy all of its features).
1. Data Collection
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as "Personal Data"):
Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third party services (as detailed in Sections 4 and 5 below).
Such data consists of connectivity, technical or aggregated usage data, such as IP address, device advertiser ID, carrier and networks, non-identifying data regarding the device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of Users of our Services.
Data received from you: you may provide us Personal Data voluntarily, such as your name and e-mail address when you contact us, your hashed password, your content and images (including details regarding your events or other announcements, if you choose to upload them to the Services), when you post on our public forums or groups, when you sign-up to receive e-mail updates, when you place any purchases via our Services, or when you choose to connect your Facebook account to our Services.
You may also provide us with Personal Data of your Recipients, namely their names and e-mail addresses, so that you could use our Services to contact and send them content you uploaded to and created through the Services.
Data received from Facebook and other channels: If you choose to connect your Facebook account to our Services, we will receive access to your full name and user ID on Facebook. You may also choose to allow us to access your images saved on Facebook, so that you could fetch these images and use them on our Services. Such access will also allow us to collect the following parameters (to the extent you defined them as "public"): your profile picture, gender, date of birth, comments on our Site, tags and tagged pictures, locale and time zone.
In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession (to learn more about our advertising practices, please read Section 4 below).
Transaction Data: Our Services allow you to place purchases. Currently all purchases must be completed via PayPal, which will then provide us with limited data concerning your order. We will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to your order, such as your name, PayPal username/e-mail, billing and shipping address, the items purchased and paid amount, in order to fulfil your purchase and for our accounting purposes.
2. Data Uses
We will use your Personal Data as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements on our Site and through other channels, improving our customer service and support operations, and protecting and securing our Users, ourselves and our Services.
Accordingly, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our Users, and allow them access to additional features;
- To provide our Users with customer care, assistance and technical support services;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on your activity on our Site and Platform, and based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;
- To contact our Users (via e-mail, Facebook, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our Users with promotional messages (such as updates regarding new features and services, etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
3. Cookies, Tracking and Advertising Uses
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Services as a whole. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the User.
To learn more about our "cookies" and related practices, and for a list of the cookies we use. Please see our Cookies Policy, available here.
Our Services also utilize advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, by deploying contextual and interest-based advertising, as well as targeting, ad measurement and attribution systems. The ads we or our advertising partners deliver may be shown within our Services or through other channels, such as third party websites and applications.
Such data includes your device advertising identifiers (e.g. IDFA, to the extent available), your IP address, cookies, pixels and other unique identifiers, data related to your connected Facebook profile (if any, such as your gender, age group, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described in Section 3 above). Please note that we do not share the data you provide us through your connected Facebook account with our advertising partners.
Please note that this Privacy Notice does not apply to the processing of your data by our advertising partners and networks. We recommend that you review their privacy policies for more information (a list of our advertising partners and networks and their policies can be found here).
How to adjust your preferences regarding cookies and interest-based advertising
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
If you wish to prevent the use of your mobile device's advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the "Privacy" or "Ads" section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the "Settings" or "Help" section in your browser menu).
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US Users), www.youradchoices.ca/choices (for Canadian Users) or www.youronlinechoices.eu (for European Users).
Please note that if you reset your cookies or opt-out of interest based advertising, you may still see advertisements in our Services, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your activity on our Services, or your language preferences. Please also note that such actions may result in a less enjoyable user experience.
4. Storage and Retention
Your Personal Data may be maintained, processed, accessed and stored by Greetings Island and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. Clear Coast Ltd. is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, Greetings Island has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
We retain your Personal Data for the period necessary in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our User and have not notified us otherwise (or deleted your account, as described in Section 8). We will also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy. If you have any questions about our data retention policy, please contact us at privacy@GreetingsIsland.com.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
5. Data Sharing
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Notice:
- Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording services, and our business, legal, financial and compliance advisors) (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
- Third Party Integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook account to the Platform, or your PayPal account to make purchases, in which case you will be bound by the terms of service and privacy notices of said third parties (e.g., PayPal or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
- Protecting Rights and Safety: We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Greetings Island, any of our Users or any members of the general public.
- Greetings Island Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Notice. In addition, should Greetings Island or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
For the removal of doubt, Greetings Island may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We will provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms. If you wish not to receive such promotional communications, you may notify Greetings Island at any time by e-mailing us at support@GreetingsIsland.com or by following the "unsubscribe", "stop" or "change e-mail preferences" instructions in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties.
8. Data Subject Rights
If you wish to exercise your rights under applicable law (e.g. the EU GDPR) to access, rectify, erase or port your Personal Data held with Greetings Island, or to revoke the authorization you granted Greetings Island to access your Facebook account – please contact us at privacy@GreetingsIsland.com.
You may also delete your User account and related Personal Data by simply logging into your User account and using the "Delete Account" feature.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. so we have proof of the identity of the person submitting the request), in accordance with our data retention policy.
Please note that in some cases, as we may rely on our Service Providers' APIs and systems, your requests may require up to a few weeks to process.
Our Services are not designed to attract children under the age of 16. We do not knowingly or intentionally collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us at privacy@GreetingsIsland.com.
10. Data Controller/Processor & Recipients Data
Certain data protection laws and regulations, such as the EU GDPR, typically distinguish between two main roles for parties processing Personal Data: the "Data Controller", who determines the purposes and means of processing, and the "Data Processor", who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Greetings Island is the "Data Controller" of its Users' Personal Data, and assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth under this Privacy Notice.
Each User is solely responsible for the security, integrity and authorized usage of their Recipients' Personal Data, and for obtaining consents or establishing other necessary legal bases, permissions and providing any fair processing notices required for the collection and usage of such data.
If you are a Recipient of any of our Users, please note that Greetings Island only processes your data solely on such User's behalf. If a Recipient would like to make any requests or queries regarding their Personal Data, we encourage then to contact such User(s) directly. For example, if you are a Recipient who wishes to access, correct, or delete data processed by Greetings Island on behalf of its Users, please direct your request to the relevant User (who is the “Controller” of such data). If requested to remove any Recipient's Personal Data, we will respond to such request within thirty (30) days. Unless otherwise instructed by our User, we will retain their Recipients' Personal Data for the period set forth in Section 5 above.
11. Updates & How To Contact Us
Updates and amendments: We may update and amend this Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you.
Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Privacy, please contact us at privacy@GreetingsIsland.com. Greetings Island's Data Protection Officer can be contacted at dpo@GreetingsIsland.com.
Greetings Island has designated Dr. Andreas Mätzler as its representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. Inquiries regarding Greetings Island's EU privacy practices may be sent to Dr. Mätzler at Schellinggasse 3/10, Vienna 1010, Austria, or by e-mail to firstname.lastname@example.org (please add the following subject to all correspondences: DPI-REP ID: 14157699). If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.