PRIVACY POLICY
Last Modified: May 25th
CONTENTS
CLAUSE
- Important information and who we are……………………………………………………………………………………….1
- The data we collect about you………………………………………………………………………………………………….2
- How is your personal data collected?………………………………………………………………………………………..4
- How we use your personal data……………………………………………………………………………………………….4
- Disclosures of your personal data…………………………………………………………………………………………….7
- International transfers……………………………………………………………………………………………………………..8
- Data security…………………………………………………………………………………………………………………………9
- Data retention………………………………………………………………………………………………………………………..9
- Your legal rights…………………………………………………………………………………………………………………….9
- Glossary…………………………………………………………………………………………………………………………..11
Introduction
Welcome to explaindio LLC’s Privacy Policy.
Your privacy is very important to us.
We have created this Privacy Policy to demonstrate our firm commitment to privacy and security.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set
out below. [Alternatively you can download a pdf version of the Policy here http://explaindio
LLC.com/explaindio LLC_privacy_policy.pdf ]. Please also use the Glossary to understand the
meaning of some of the terms used in this Privacy Policy. - IMPORTANT INFORMATION AND WHO WE ARE
- THE INFORMATION WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL INFORMATION COLLECTED
- HOW WE USE YOUR PERSONAL INFORMATION
- DISCLOSURES OF YOUR PERSONAL INFORMATION
- INTERNATIONAL TRANSFERS
- INFORMATION SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY]Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how explaindio LLC collects and processes your
personal information through your use of the explaindio LLC corporate website at http://explaindio
LLC.com, its Support website at http://support.explaindio.com/, and their respective subdomains
(collectively the “Website”), including any information you may provide through the Website when
you access some of our services without creating an account with us, when you register to open a
vendor or affiliate account to sell/promote products and/or pay a monthly fee to subscribe to our
services, when you search our Website, when you register to open a Support account with us, when
you submit a Support ticket.
Please note that this website is not intended for persons under 18 years of age. No one under age
18 may provide any information to or on this Website. We do not knowingly collect personal
information from individuals under 18. If you are under 18, do not use or provide any information on
this Website or on or through any of its features, use any of the interactive or public comment
features of this Website or provide any information about yourself to us, including your name,
address, telephone number, email address, or any screen name or user name you may use. If we
learn we have collected or received personal information from a person under 18 without verification
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of parental consent, we will delete that information. If you believe we might have any information
from or about an individual under 18, please contact us here http://support.explaindio.com//.
It is important that you read this Privacy Policy together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or processing
personal information about you so that you are fully aware of how and why we are using your
information. This Privacy Policy supplements the other notices and is not intended to override them.
Controller
[explaindio LLC Group is made up of different legal entities, details of which can be found here
http://explaindiollc.com/group.txt . This Privacy Policy is issued on behalf of the explaindio LLC
Group so when we mention “explaindio LLC”, “we”, “us” or “our” in this Privacy Policy, we are
referring to the relevant company in the explaindio LLC Group responsible for processing your
information.] explaindio LLC, LLC is the controller and responsible for your personal information.
If you have any questions about this Privacy Policy, including any requests to exercise your legal
rights, please contact us here http://support.explaindio.com//
If you are based in the European Union, you also have the right to make a complaint at any time to
your local supervisory authority for data protection issues. We would, however, appreciate the
chance to deal with your concerns before you approach the regulator so please contact us at
http://support.explaindio.com// in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
This version was last updated on May 25th
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We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will
post the revised Privacy Policy to our Website and the last revision date of revision will be updated
so that you will always be able to understand what information we collect, how we use your
information, and under what circumstances we may share your information with others. We will
notify you of any material changes by way of a pop-up notice on the Website announcing that the
Privacy Policy has changed pointing the changes to your attention AND/OR by the way of email
AND/OR web app notification.
It is important that the personal information we hold about you is accurate and current. Please keep
us informed if your personal information changes during your relationship with us.
Third-party links
This Website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share information about you.
We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our Website, we encourage you to read the privacy notice of every website you
visit.
Please note that we also do not control third parties’ collection or use of your information to serve
interest-based advertising. However these third parties may provide you with ways to choose not to
have your information collected or used in this way. If you are based in the United States you can
opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the
NAI’s website at http://optout.networkadvertising.org. If you are based in the European Union you
may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at
https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at
http://www.easa-alliance.org.
Public Forums
Our Website offers publicly accessible blogs or community forums. You should be aware that any
information you provide in these areas may be read, collected, and used by others who access
them. To request removal of your personal information, if you are EU from our blog or community
forum, contact us by posting request on our our helpdesk here http://support.explaindio.com/.
Social Media Features
- GLOSSARY]Important information and who we are
- Our Website includes Social Media Features, such as the Facebook Like button. These
Features may collect your IP address, which page you are visiting on our site, and may set a
cookie to enable the Feature to function properly. Social Media Features are either hosted by
a third party or hosted directly on our Website. Your interactions with these Features are
governed by the privacy policies of the companies providing them.The data we collect about
you
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
We may collect, use, store and transfer different kinds of personal information about you which we
have grouped together follows:
Identity Data includes first name, maiden name, last name, username or similar identifier,
[marital status], title, date of birth, and gender.
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Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services
you have purchased from us.
Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number,
your login data, browser type and version, time zone setting and location, browser plug-in types
and versions, operating system and platform and other technology on the devices you use to
access this Website.
Profile Data includes your username and password, [photo], purchases or orders made by you,
your [location,] interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website and services, such as the
buttons, controls, products and ads you click on, pages of our application or Website that you
visit, the time spent on those pages, your search queries, the dates and times of your visits, but
also about the webpage you were visiting before you came to our Website [app(s)?] and the
webpage[,app(s)?] you go to next.
Marketing and Communications Data includes your preferences in receiving marketing from
us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal information but is not considered
personal information in law as this information does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific Website feature. However, if we combine or connect Aggregated Data with your personal
information so that it can directly or indirectly identify you, we treat the combined data as personal
information which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
If you fail to provide personal information - Where we need to collect personal information by law, or under the terms of a contract we
have with you and you fail to provide that information when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example, to provide you
with our services). In this case, we may have to cancel a service you have with us but we will
notify you if this is the case at the time. How is your personal information collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal
data you provide when you :
create an account with us;
access some of our services;
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register to open a Support account with us;
submit a Support ticket;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us some feedback.
Purchase product from vendor/seller on explaindio LLC platfrom
Automated technologies or interactions. As you interact with our Website, we may
automatically collect Technical Data about your equipment, browsing actions and patterns. We
collect this personal data by using cookies, server logs and other similar technologies. [We may
also receive Technical Data and Usage Data about you if you visit other websites employing our
cookies.] Please see our Cookie Policy http://explaindio LLC.com/cookie_policy.pdf for further
details].
Third parties or publicly available sources. We may receive personal information about you
from various third parties and public sources as set out below :
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as perfectaudience.com based outside] the EU; and
(c) search information providers such as Google and Bing based outside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery
services [such as PayPal and Stripe based outside the EU.
Identity and Contact Data from our partners, data brokers or aggregators BBC Systems inc
based outside the EU]=.
Identity and Contact Data from publicly availably sources such as Facebook, Twitter, any public
websites based outside and inside of the EU. - Facebook Pixel.How we use your personal information
We will only use your personal information when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
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Generally we do not rely on consent as a legal basis for processing your personal information other
than in relation to sending third party direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time by contacting us at
http://support.explaindio.com//.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal
information, and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on
the specific purpose for which we are using your information. Please contact us
http://support.explaindio.com// if you need details about the specific legal ground we are relying on
to process your personal information where more than one ground has been set out in the table
below.
Purpose/Activity Type of data Lawful basis for processing including
basis of legitimate interest
To register you as a new vendor
or affiliate
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order
including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to recover debts due to us)
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or Privacy Policy
(b) Asking you to leave a review
or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate interests
(to keep our records updated and to study
how customers use our services)
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
(to study how customers use our services,
to develop them and grow our business)
To administer and protect our
business and this Website
(including troubleshooting, data
(a) Identity
(b) Contact
(a) Necessary for our legitimate interests
(for running our business, provision of
administration and IT services, network
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a n a l y s i s , t e s t i n g , s y s t e m
maintenance, support, reporting
and hosting of data)
(c) Technical security, to prevent fraud and in the
context of a business reorganization or
group restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website
content and advertisements to
you and measure or understand
t h e e f f e c t i v e n e s s o f t h e
advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests (to
study how customers use our services, to
develop them, to grow our business and to
inform our marketing strategy)
To use data analytics to improve
our website, services, marketing,
customer relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to
define types of customers for our services,
to keep our Website updated and relevant,
to develop our business and to inform our
marketing strategy)
To make suggestions and
recommendations to you about
services that may be of interest to
you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to
develop our services and grow our
business)
Marketing
We strive to provide you with choices regarding certain personal information uses, particularly
around marketing and advertising. [We have established [a privacy center where you can view and
m a k e c e r t a i n d e c i s i o n s a b o u t y o u r p e r s o n a l d a t a u s e
https://support.explaindio.com/support/solutions/13000002972 OR the following personal
information control mechanisms]:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or
purchased services from us or if you provided us with your details when you entered a competition
or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal information with any
company outside our company for marketing purposes, including service providers who perform
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marketing services on our behalf, such as conducting surveys, sending communications to you on
our behalf, or serving advertisements to you.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into
the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by
following the opt-out links on any marketing message sent to you o] by contacting us
http://support.explaindio.com//.
Where you opt out of receiving these marketing messages, this will not apply to personal
information provided to us as a result of a service purchase, service experience or other
transactions.
California residents: Under California Law SB27, California residents have the right to receive,
once a year, information about third parties with whom we have shared information about you or
your family for their marketing purposes during the previous calendar year, and a description of the
categories of personal information shared. To make such a request, please contact us at
http://support.explaindio.com// send and please include the phrase “California Privacy Request” in
the subject line of request, and the domain name of the Website you are inquiring about, along with
your name, postal address, and email address. We will respond to you within 30 days of receiving
such a request.
Do Not Track “DNT” Signals
While we take all reasonable steps to protect the privacy of our Website visitors, we cannot promise
that the current limitations of our online applications programming will address every browser setting
or honor every personal browser preference. In particular, we have not implemented the necessary
program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications
programming is refined, we will take all reasonable steps to honor such requests in the future.
Please return to this Privacy Policy for further updates on this topic.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set
or access cookies. If you disable or refuse cookies, please note that some parts of this Website may
become inaccessible or not function properly. For more information about the cookies we use,
please see http://explaindio LLC.com/cookie_policy.pdf
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us at http://support.explaindio.com//.
If we need to use your personal information for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.
8 - Please note that we may process your personal information without your knowledge or
consent, in compliance with the above rules, where this is required or permitted by
law.Disclosures of your personal information
We may have to share your personal information with the parties set out below for the purposes set
out in the table in paragraph 4 above.
Internal Third Parties as set out in the [Glossary].
External Third Parties as set out in the [Glossary].
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal information in the same
way as set out in this Privacy Policy. - We require all third parties to respect the security of your personal information and to
treat it in accordance with the law. We do not allow our third-party service providers to use
your personal information for their own purposes and only permit them to process your
personal information for specified purposes and in accordance with our
instructions.International transfers
We share your personal information within our company. This will involve, if you are based in the
European Union, transferring your data outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so
their processing of your personal information will involve a transfer of data outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the
EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the
following safeguard is implemented :
We will only transfer your personal information to countries that have been deemed to provide
an adequate level of protection for personal information by the European Commission.
.
9 - Please contact us if you want further information on the specific mechanism used by
us when transferring your personal information out of the EEA. Data security
We have put in place appropriate security measures to prevent your personal information from
being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition,
we limit access to your personal information to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal information on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so. - However, you should note that no transfer of data over the Internet is completely secure. While we
use reasonable efforts to protect your personal information on our systems, when the information
is transferred over the Internet, it may be accessed and used by unauthorized third parties.
explaindio LLC has no control over the performance, reliability, availability or security of the
Internet and does not warrant that any information transfer via the Internet or any communication
through the Internet is secure. explaindio LLC shall not be liable for any disclosure, unauthorized
use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception,
corruption, intervention, misuse or alteration of any personal information due to any reason
beyond explaindio LLC’s reasonable control.
Data retention
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal information, we consider the amount,
nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use
or disclosure of your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and the applicable
legal requirements.
In some circumstances you can ask us to delete your information: see [Request erasure] below for
further information.
In some circumstances we may anonymize your personal information (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this information
indefinitely without further notice to you. - EU residents: Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
information. Please click on the links below to find out more about these rights:
Request access to your personal information.
Request correction of your personal information.
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Request erasure of your personal information].
Object to processing of your personal information.
Request restriction of processing your personal information.
Request transfer of your personal information].
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us at
http://support.explaindio.com//
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal information (or to exercise any of your other rights). This is a
security measure to ensure that personal information is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further information in relation to your
request to speed up our response.
Time limit to respond - We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business
to enable us to give you the best service and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal information for our legitimate interests. We do not use your
personal information for activities where our interests are overridden by the impact on you (unless
we have your consent or are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any potential impact on you in
respect of specific activities by contacting http://support.explaindio.com//].
Performance of Contract means processing your information where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before entering
into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where
it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the explaindio LLC Group acting as joint controllers or processors and who are
based US and provide IT and system administration services and undertake leadership reporting.
External Third Parties
Service providers [acting as processors] based US, Ukraine, India, Romania, Sri Lanka,
Belarus, Venezuela, Kosovo, Mexic, Argentina, Philippines who provide IT and system
administration services.
Social networking sites [acting as processors] based in the United States to which you have
linked your account.
Professional advisers [acting as processors or joint controllers] including lawyers, bankers,
auditors and insurers based US an France who provide consultancy, banking, legal, insurance
and accounting services.
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EU RESIDENTS: YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal information (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal information we hold about you and to
check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have
any incomplete or inaccurate information we hold about you corrected, though we may need to
verify the accuracy of the new information you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal information where you have successfully
exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal information to comply with
local law. Note, however, that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular situation which makes you want
to object to processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your personal information for
direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to
suspend the processing of your personal information in the following scenarios: (a) if you want us to
establish the information’s accuracy; (b) where our use of the information is unlawful but you do not
want us to erase it; (c) where you need us to hold the information even if we no longer require it as
you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your
information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you,
or a third party you have chosen, your personal information in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which you
initially provided consent for us to use or where we used the information to perform a contract with
you.
Withdraw consent at any time where we are relying on consent to process your personal
information. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, we may not be able to provide certain services
to you. We will advise you if this is the case at the time you withdraw your consent.
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