Privacy Statement for Personally Identifiable Information of Optinly.

Updated: June 13th, 2019

Optinly and its affiliates (collectively “Optinly”, “we” and “us”) is committed to protecting your privacy and processing your personally identifiable information (referred to as “PII” or “personal data” or “personal information”) with transparency.

We offer products and services that enable merchants to create and run effective marketing campaigns and increase their Return on Investment.

This Global Privacy Policy statement describes the types of Personal Data we collect through our products and services (“Services”) and via our online presence, which includes our main website at Optinly, as well as services and websites that we enable Internet users to access (collectively, our “Sites” or “Offerings”). This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.

For the purposes of this statement, personal information is understood to be any information which is relevant to you, with which your identity is or can be identified and which include, for example, your name, email address, physical address, VAT number, IP address (only when we have collected it in conjunction with directly identifying information) or the information you submit in your support requests.

This Privacy Policy is provided in a layered format. Click through to jump to a specific section.

1. Overview
2. Personal Data We Collect
3. How We use the Information We Collect
4. How We disclose Personal Data
5. Your Control and Choices
6. Accessing and Updating your Personal Information
7. Security and Retention
8. International Data Transfers
9. Use by minors
10. Updates to this Privacy Policy and Notifications
11. Links to other websites
12. Contact Us

1. Overview

Optinly is registered in Singapore with the purpose of providing software and services, with registered address 09-14 High Street Plaza, High Street, Singapore, 179433.

If you have any questions about your use of personal information you can contact the Data Protection Officer through the Contact Us form.

If you want a copy of your personal information kept on file (“data portability right”) or delete the personal information we keep on file for you (“right to be forgotten”), please log into our site and use the Delete Account option or just send us a request through the contact form.

2. Personal Data We Collect

a. Personal Data that we collect about you.

Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:

• When you register for an account we collect your full name, email address, and account log-in credentials.
• When you fill-in our online form to contact our sales team, we collect your full name, work email, country, and anything else you tell us about your company, requirements and timeline.
• Payment Information. When you purchase the Services, we will also collect transaction information, which may include your billing and mailing address, and other payment-related information (“ Payment Information”).
• Support ticket information. Any identifiable information you provide when requesting support through our ticket system’s private tickets feature including but limited to connection information to your site(s) and any other personally identifiable information you may volunteer. We use that information to provide you with technical and account support and, generally, to answer your questions and address your requests. Please note that when filing a public support thread via the community forum, you have no reasonable expectation of privacy and as such any information volunteered in a public support thread is not subject to our privacy statement.

When you respond to our emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call us.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Sites.

Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
• Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.

We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.

To learn more about the cookies that may be served through our Sites and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.

3. How We Use the Information We Collect

We use your information in the following ways:

• To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Offerings (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits);
• To process your inquiries and otherwise deliver customer service;
• To process your payments, we share and use Payment Information
• To control unauthorized use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
• To analyze trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole;
• To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in Section (Your Controls and Choices);
• To deliver you advertising, including by serving and managing ads on the Offerings or on third party sites and to tailor ads based on your interests and browsing history. Please see Section (Your Controls and Choices) for additional information on how to manage the ads you see; and
• In the manner described to you at the time of collection or as otherwise described in this Privacy Policy.

When you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with Google AdWords and other advertising networks. To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

4. How We Disclose Personal Data.

We do not sell, trade, share or transfer your personal information to third parties. We share your Personal Data with trusted entities, as outlined below.

a. Optinly.

We share Personal Data with other Optinly entities in order to provide our Services and for internal administration purposes.

b. Service providers.

We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the the United States of America.

We may share your personal information with a third party if we have your consent to do so.

c. We share Personal Data as we believe necessary:

(i) to comply with applicable law, or payment method rules;

(ii) to enforce our contractual rights;

(iii) to protect the rights, privacy, safety and property of Optinly, you or others; and

(iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your Controls and Choices.

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out.

If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

b. How you can see or change your account Personal Data.

If You would like to review, correct, or update Personal Data that you have previously disclosed to us, You may do so by signing in to your account or by contacting us.

c. Blocking Cookies.

You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so. For more information, please see our Cookie Policy.

d. How We Respond to Do Not Track Signals.

Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Offerings do not respond to this type of signal.

6. Accessing and Updating Your Personal Information

When you use the Offerings, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so, please contact us with your name and the information requested to be accessed, corrected or removed, or if you are using the Service, sign in to your account, go to your profile, and make the desired changes. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please note that if you cease using the Service or we terminate your access to the Service in accordance with your Customer Agreement, you may no longer have the ability to access or update your information.

We may retain your information as necessary to support the Offerings, comply with our legal obligations or resolve disputes. Note that content you post may remain on the Offerings even if you cease using the Offerings or we terminate your access to the Offerings.

7. Security and Retention.

The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

8. International Data Transfers.

We are a global business. We may from time to time transfer your personal information to other countries outside the United States and make it accessible to our parents, subsidiaries, affiliates and third party service providers internationally. We will protect your personal information in accordance with this Privacy Policy wherever it is processed. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy.

9. Use by Minors.

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.

10. Updates To this Privacy Policy and Notifications.

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Stripe Dashboard, email address and/or the physical address listed in your account.

11. Links To Other Websites.

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

12. Contact Us

If you have questions or need to contact us about this Privacy Policy, please email us at team@lucidreach.tech or to the physical address mentioned at Section 1.