Privacy Policy
Privet's Promise to its customers
Privet will never sell your data. Privet's sole source of revenue is through the subscription services our customers subscribe to.
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Minimize Data Footprint
Privet uses its resources to keep your private data out of the hands of companies who put your data privacy and security in jeopardy. We accomplish this by reaching out to companies on your behalf to ask them to delete the data they have stored on you in addition to asking them to not sell your data.
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What Type of Data we collect
Privet receives, collects and stores any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. When absolutely necessary, we also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, product reviews, recommendations, and personal profile.
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How we collect data
When you conduct a transaction on our website, as part of the process, we collect personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated above only.
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Why we collect data
We collect such Non-personal and Personal Information for the following purposes:
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To provide and operate Privet's services;
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To provide our users with ongoing customer assistance and technical support;
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To be able to contact our visitors and users with general or personalized service-related notices and promotional messages;
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To create aggregated statistical data and other aggregated and/or inferred non-personal Information, which we or our business partners may use to provide and improve our respective services;
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To comply with any applicable laws and regulations.
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How do we store, use, share and disclose our site visitors' personal information?
Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
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How do we communicate with our site visitors?
We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you. For these purposes we may contact you via email, telephone, text messages, and postal mail.
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How does Privet use cookies and other tracking tools?
Third-party services, such as Google Analytics or other applications offered through the Wix App Market, places cookies or utilizing other tracking technologies through Wix´s services, may have their own policies regarding how they collect and store information. As these are external services, such practices are not covered by the Wix Privacy Policy.
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(i) Subscription to a Privet Plan
If you subscribe to a Privet Plan your payment may be handled by Privet's partners. We provide these companies access to data required to process the payment for a Privet subscription. Your personal data may be stored by Privet and/or these payment providers as required by tax regulations and/or payment network requirements (e.g. Visa, Mastercard, etc.) For more information on how payment partners may use your data, please consult Title 2 on Sub-Processors.
(ii) Data Deletion Requests
Privet App offers you the ability to have Privet contact other companies who sell and store your data to request they remove the data they have stored on you.
Due to the large number of companies that buy, sell, and store your data Privet will contact companies you may have never heard of. If these companies are required by their domestic legisltation to abide by these Data Deletion requests they will remove any data they hae stored on you that doesn't direclty impact the services they currently provide you with. At no point will Privet store any of this data.
Section 2. Privet App Analytics
The Privet App collects analytics information to ensure that our product works correctly on different devices and operating systems. This data also helps us improve the quality of our product and make your experience better. This includes data like the type of device you’re using, the operating system, event stamps and error logs.
You can opt-out from anonymous Privet App analytics at any time, directly from the Privet App, and we will no longer collect analytic data from your device.
We do not track or store any of your personal data with this analytic tool. Instead, to distinguish one user from another in an anonymous way, we use a unique identifier called “deviceID” that is linked to your device and your use of the Privet App.
Section 3. Support
Privet Privacy is by your side to help you control your privacy. Therefore, if you have any questions or concerns regarding Privet, this Privacy Policy or your privacy rights, you can contact our support team directly on our site's chat services, or by sending an email to: support@privetprivacy.com.
Section 4. Surveys
We sometimes conduct surveys to get feedback on our products and services. When conducting such surveys, we might collect anonymous information such as country or age range to understand demographics of our user base survey participants include in their survey answers. On some rare occasion, we give you the possibility to provide us your email address on an opt-in basis if you want the opportunity to chat with a team member or if you want to receive updates regarding our services. In such event, we only process your email address for the purpose provided for in the survey, and for as long as strictly necessary. We do not sell it or transfer it to any third-party.
You can opt-out from any further communication, rectify, and/or erase your email address directly in any received communication, or by sending us an email to support@privetprivacy.com.
Section 5. Functioning cookies on our websites
We have installed cookies on our websites available to collect your IP address only for strictly necessary purposes to enable our websites to work properly as described below.
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We do not have any other cookies on our websites (such as tracking or advertising cookies).
You can refuse the use of cookies at any time by adjusting the settings of your browser (Internet Explorer, Safari, Firefox, Chrome) by selecting the “cookies” option in the “Help” function to obtain information about the location of the cookie folder. Please note that disabling cookies may limit access to certain features or pages of the Privet Privacy websites.
Section 6. Privet Privacy’s ads
You might have noticed some ads for Privet Privacy on websites or apps you have been on. In order to understand if you have subscribed to Privet after clicking on one of our ads, and if so, what exact ad, we collect your IDFA and IP address when you start using the Privet App together with certain events, for legitimate business purposes. Events consist of information on whether you have taken on a Privet subscription plan or not.
Once collected, Your IDFA/IP address and the collected events are immediately sent to our ad campaign partner, Singular, without Privet storing them. This information is shared with ad networks Privet works with to display ads (such as Google Ads, Apple Ads, Twitter Ads and Facebook Ads) to confirm ad campaign attributions.
Please note that you can opt-out from such data usage at anytime by sending us an email to support@privetprivacy.com.
TITLE 2: Sub-Processors
Third-party services Privet relies on, and what data they might store about you.
We only share your personal data with the services we rely on, if strictly necessary to provide you with our privacy and security services.
Where we need to share your personal data with our third-party services, we have chosen them with a lot of care, to make sure they take privacy as seriously as we do and that they only use your personal data for the purposes we have instructed them to do. We might also have executed data processing agreement with them to regulate how such service providers use your personal data. This data processing agreement was implemented thanks to the GDPR, CCPA, and the Australian Privacy Principals. In the event where such service providers are limiting their data processing agreements to European, UK, Australian, or Californian users, we are negotiating to extend such protection to all our users wherever located.
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Section 1. Freelancers
From time to time, we may use freelancers based in the USA or Europe to help us for specific tasks notably to our support team. These freelancers might process personal data belonging to you under our strict instructions. We chose very carefully the freelancers that work with us, and they all sign a data protection agreement containing security requirements to ensure the safety of your personal data before starting to work for Privet. For more information, please contact us.
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TITLE 3 - Other information about your data
Section 1. Personal Data transfers EU/UK/Swiss-USA (null until Privet receives certification)
PRIVACY SHIELD UPDATE: ON JULY 16th, 2020, THE EUROPEAN COURT OF JUSTICE HAS DEEMED THE PRIVACY SHIELD NO LONGER AN ADEQUACY DECISION TO MAKE TRANSFERS OF PERSONAL DATA FROM THE EU TO THE USA. WE ARE ACTIVELY WORKING ON THIS TOPIC TO CONTINUE ENSURING THE PROTECTION OF OUR EUROPEAN USERS’ PRIVACY.
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Until then, please note that as provided under article 49 of the GDPR, we have the obligation to inform you of the possible risks of the transfer of your personal data to the USA due to the absence of an adequacy decision or other appropriate safeguards since such invalidation. By using the Privet App, you guarantee having been informed of such risks and understanding them.
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Since Privet Inc is located in the USA, we might transfer some of your personal information from the European Union, the United Kingdom or Switzerland, to the USA. We comply and have self-certified with the EU/UK-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the European Economic Area, the United Kingdom and Switzerland to the United States.
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If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will take precedence. You can also learn more about Privacy Shield at www.privacyshield.gov.
As described in the Privacy Shield Principles, Privet is responsible for personal data that it receives and subsequently transfers to third parties. If third parties that process personal data for us do so in a manner that does not comply with the Privacy Shield Principles, we are responsible for such failure, unless we prove that we are not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Privet commits to resolve complaints about our collection or use of your personal information. EU, British and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should contact Mary J. Hildebrand, CIPP/US, CIPP/E by email at MHildebrand@lowenstein.com.
Privet has further committed to refer unresolved Privacy Shield complaints to ICRD-AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICRD-AAA are provided at no cost to you.
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As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Privet is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission
Section 2. Extraordinary disclosures
We may be obligated to disclose your personal data if we determine that such disclosure is reasonably necessary and required:
(a) to comply with applicable laws or judicial orders;
(b) to protect the rights or property of Privet or other users of our services, including in investigating any violation or potential violation of the law, this Privacy Policy, or our TOS.
We will always keep in mind that your data should be protected therefore we will always fight unjustified requests and be transparent about them.
If Privet or its business or assets are acquired by, or merged into, another company, that company will possess any personal data in our possession at such time and will assume our rights and obligations under this Policy.
Section 3. Security of data
We take security very seriously and therefore have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk linked to our processing of all data as described hereabove. To implement such measures, we have taken into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for your rights and freedoms as natural persons.
Section 4. CCPA
We have provided you with all necessary information as provided under the CCPA:
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we update our privacy policy every 12 months;
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we have posted a conspicuous link to the privacy policy on our website;
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we have informed you of the list of personal data that Privet might have collected about you over the last 12 months;
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we have informed you on how to access or delete your personal data, and will not discriminate against you if you exercise your rights under the CCPA;
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we have informed you that we do not sell your personal data.
TITLE 4 – Your Rights
As a matter of principle, you can exercise all your rights free of charge.
Section 1. Access/Rectification/Deletion/Portability of your personal data
On a general basis, you can access, rectify, or delete your personal data directly through the Privet App, or through the service providers we are relying on as described above or by contacting the support team directly through our application.
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If you are unable to complete your requests through the Privet App or such services, you can send a detailed message explaining your request to us at: support@privetprivacy.com.
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Privet will inform you if it can act on your request or if you need to do it directly in our application, with our support. Privet would also like to inform that the request you send for the exercise of your rights might be kept for follow-up purposes.
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• Specification for deletion :
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the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed ;
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you withdraw the consent you have previously given ;
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you object to the processing of your personal data and there is no legal reason for such processing ;
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the processing of personal data does not comply with the provisions of the applicable legislation and regulations ;
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your personal data have been collected in relation to the offer of information society services to children under 16 years of age.
Please note that the exercise of this right may not be possible when the retention of your personal data is necessary for compliance with statutory or regulatory provisions and in particular for example for the establishment, exercise or defense of legal claims.
Section 2. Restriction of processing
You may request restriction of processing of your personal data in the cases provided for by laws and regulations. You can exercise this right directly through the Privet App or by contacting the support team directly through the application.
If you are unable to complete your requests through the Privet app or such services, you can send a detailed message explaining your request to us at: support@privetprivacy.com.
Section 3. Post-mortem Guidelines
You have the possibility to give guidelines in relation to the storage, deletion and communication of your personal data after your death to a certified trusted third party in charge of ensuring that the wishes of the deceased are respected in compliance with the conditions laid down in the applicable legislation.
You can exercise this right directly through the Privet App or by contacting the support team directly through the application.
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If you are unable to complete your requests through the Privet application or such services, you can send a detailed message explaining your request to us at: support@privetprivacy.com.
Section 4. Changes to the privacy policy
Any changes we make to the Privacy Policy in the future will be posted on this page and, when mandatory, notified to you directly in the Privet App.
Section 5. Liability and Disclaimers
Limits on liability and disclaimers applicable to our privacy policy are provided under our TOS.
Section 6. Information for European users
Pursuant to Article 27 of the General Data Protection Regulation of the European Union, we have appointed ePrivacy GmbH, as our European Representative, which office is located at:
ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany
We also want to inform you that you are entitled to lodge any complaint with regards to privacy matters in relation with our activity to your local data supervisory authority.
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