2. Country Of Processing
We operate the Services from the United States of America (USA) and our data collection and processing activities takes place in the USA. We store and otherwise process data (including personal data) through third-party cloud service providers and other service providers which may be located or operate in other countries.
3. How We Collect and Use Your Information
a. Information That You Provide Directly or Authorize Someone Else to Give Us. We may ask you to provide certain information including, but not limited to your name, postal address, email address, telephone number, password, third-party social networking service username and password, birthday, and other information. We retain messages you send through the Service, and other information you provide to us. We use this information to operate, maintain and provide to you the features and functionality of the Service, and as further detailed below.
b. Information Collected or Received From Third Parties. We receive information about you from third parties, including, but not limited to, third-party social networking services, such as Facebook, Twitter, Twitch, Google and others when you sign up for the Services through your account with such third parties or through a service linked to your account with such services. We may also receive information from our third party service providers, such as our payment processors, website analytics providers, or others providing features or functionality related to our Service, or who assist us with marketing or other promotional efforts. You should always review and, if necessary, adjust your privacy settings on third-party services such as social media services before linking or connecting them to the Service.
c. Platform Generated Data. Various different types of data are collected automatically when you use our Services. This may include some of the types of information described below, and generally includes any data which may be generated, recorded or automatically collated in the course of providing the Service including, without limitation, aggregated or anonymized data that cannot be linked to individual end users, data relating to the frequency and mode of use of the features and functionality of the Service by end users, preference settings and personalization of the Service by end users, the time spent on different elements of the Service, the geographical location of end users, types of browsers and devices and other technical and statistical information derived from the operation of the Service
e. Cookies and Similar Technologies.
(ii). Log File. Log file information is automatically reported by your browser each time you access a web page. When you access or use the Service, our servers may automatically record certain log file information, including but not limited to your web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, and pages viewed.
(iii). Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) allow for the tracking of a user's response to an email or usage of a website in a manner that does not reveal personally identifiable information. We may use clear GIFs or similar technologies to assess responses to emails and usage of the Service. For example, we may use clear GIFs to track when emails are opened and which links are clicked by recipients. You can disable certain abilities of clear GIFs to capture information by blocking cookies.
(iv). Device Identifiers. When you access or use the Service using a mobile device, we may access, collect, monitor and/or remotely store one or more "device identifiers," such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation on the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
(v). Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Certain advertising identifiers may be modified or disabled by users in the operating system's settings.
(vi) Use of Certain Service-Type information. We may use information from cookies, log files, device identifiers, location data, clear GIFs and other tools to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the Service; (ii) provide custom, personalized content or information to you or others; (iii) monitor the effectiveness of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.
f. Location Data. When you access or use the Service using a mobile device, we may access, collect, monitor and/or remotely store "location data," which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled
g. Commercial Communications. Insofar as permitted under applicable law, we may use the information we collect or receive to communicate directly with you in relation to the Services or related services we offer. Subject to your consent to receiving such communications, we may use the information to communicate with you in relation to other services that we and our affiliates offer. For example, we may use the information to send you emails containing newsletters, promotions and special offers. We may also use the information to send you Service-related notices (e.g., account verification, technical and security notices).
h. Use of information with Your Consent. We may use your information for any other purpose for which you provide consent.
4. The Purposes For Which We Use Your Personal Information
The purposes for which we collect and store your personal information are the following:
a. To enable us to deliver the Services to you and to enable you to use them efficiently;
b. Insofar as permitted under applicable law, to communicate with you in relation to the Services and other services that we or our affiliates offer;
c. Where you sign up for the Services through an account with a third-party content or platform provider, to report to that third party and to communicate with it in relation to your activities on the platform or in relation to the content;
d. To personalize, test, monitor, improve and upgrade the Services offered to you;
e. To assist law enforcement and respond to subpoenas;
f. To meet our legal obligations and the regulatory requirements to which we are subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties; and
g. For our internal business purposes, such as compiling and analyzing usage information for general operational, statistical, and business purposes.
5. Legal Basis For Processing Your Information
The processing of your information is lawful on the basis of the following:
a. Where relevant, your express consent (if your consent is requested);
b. The fulfillment of our contractual obligations to you or at your request prior to entering into a contract with us, where we process your information at your request as part of the Service;
c. Compliance with legal obligations to which we are subject, including to comply with legal process (see further below); or
d. Our legitimate interests in (among other things) providing and administering the Service, conducting commercial research, improving and maintaining the Service, personalizing and tailoring content made available to you through the Service, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our rights or property, required institutional risk control, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the Service.
6. How We May Share Your Information
b. Business Associates and Service Providers. We may share information about you with third-party business associates and service providers that perform services on our behalf in connection with the Service. Where your information is shared with such third parties, we ensure that the third party service provider will deal with your information only on our behalf and on our written instructions and solely for the benefit of our business (and not for its own benefit).
c. Business Change. If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to successor party or parties in connection with such transaction or change in ownership.
e. Sharing information. We may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party business associates who may use such information for the purposes described in the section titled "How We Collect and Use information."
f. Aggregated data. As mentioned above, we may also aggregate and anonymize or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of the Service and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.
7. How We Protect Your Information
We take a certain physical, technological and administrative measures to protect the information you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered or destroyed. Email sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email. We cannot guarantee that transmissions of your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.
8. Your Choices About Your Information
Controlling Your Settings. You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from us by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails concerning your relationship or dealings with us.
Do Not Track. At this time, we do not recognize "do not track" signals sent from web browsers. In some cases, your browser may offer a “Do Not Track” option, which allows you to signal to operators of websites, mobile applications, and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites and mobile applications and services. Disabling tracking mechanisms may disable certain features of the Service. To disable tracking, please consult the documentation for you browser, operating system or mobile device. For some devices, it may not be possible to disable tracking mechanisms. You may also disable tracking by certain third-party services by opting out:
Google Analytics https://tools.google.com/dlpage/gaoptout/
9. How Long We Keep Your Information
We retain your information as long as you remain registered with the Service and for a commercially reasonable time thereafter as necessary for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law. If you close your account with the Services, all personal information we hold about you (except to the extent it resides in back-up files) will be anonymized so that any information remaining in our records will no longer be identifiable with a specific individual.
10. Children's Privacy
Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from an individual under age 13. If You are under the age of 13, please do not submit any personal information through the Service. If You have reason to believe that We may have accidentally received personal information from an individual under age 13, please contact us immediately at firstname.lastname@example.org.
11. Third-Party Sites And Services
12. EU and UK Privacy Rights
Users based in the United Kingdom or the European Union have the following legal rights in respect of their information:
a. The right to require Maestro to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
b. The right to require Maestro to rectify inaccurate information without undue delay;
c. The right to request the erasure of their information. Subject to certain conditions, Maestro may be required to erase the information in response to such request where: I. the information is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to terminate his or her use of the Service; II. where the processing of the information is based on the user’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘How We May Share Your information’ sections above no longer apply), if the user withdraws his or her consent; or III. the user objects to the processing of his or her information and there are no overriding legitimate grounds for the processing.
d. Where Maestro has disclosed the information of a UK or European Union user to a third party and the user requests the erasure or rectification of the data, Maestro will take all reasonable steps to inform the third party of such request.
e. The right to restrict Maestro from processing their information in certain circumstances, such as where the accuracy of that information is disputed or an objection has been raised (see below). In such circumstances, Maestro will only process that information with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
f. The right to receive their information from Maestro in a structured, commonly used and machine-readable format;
g. The right to object to the processing of their information by Maestro where:
h. Maestro has relied on the ‘legitimate interest’ basis for processing that information (see paragraph 6(d) above), in which case we will immediately stop processing the user’s information unless we have compelling legitimate grounds which override the interests, rights, and freedoms of the user; or the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes.
i. The right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides. The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
j. The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
13. Additional California Privacy Notice/Rights
As required by the California Consumer Privacy Act (“CCPA”), below is a table describing the categories of personal information we have collected in the prior 12 months, as well as the categories of sources, business, and commercial purposes for which we collect and use the data, and the categories of recipients with whom we may share the information.
|Categories of Personal Information||Category of Sources||Business Purpose||Commercial Purpose||Category of Recipients|
|Identity & Contact Information||End users, Customers||Service provision & improvement, personalization, profiles, customer service, internal processing, security, compliance, other business purposes||Marketing communications, targeted advertising||Customers, service providers, advertising platforms, lawful recipients|
|Financial Information||Payment processors||Service provision & improvement, customer service, internal processing||N/A||Service providers, lawful recipients|
|Commercial Information||End Users, Customers||Service provision & improvement, personalization, profiles, customer service, internal processing, compliance, other business purposes.||N/A||Customers, service providers, lawful recipients|
|Demographics||End users, Customers, service providers, automatically collected, aggregators||Service provision & improvement||Marketing communications||Customers, service providers, lawful recipients|
|Location Data||End users, Customers, service providers, automatically collected||Service provision & improvement, personalization, profiles, customer service, internal processing, security, compliance||Marketing communications||Customers, service providers, lawful recipients|
|Inferences and Behavioral Data||Data we create, Customers, End Users||Service provision & improvement, personalization, profiles customer service, internal processing, security, compliance||Marketing communications, targeted advertising||Customers, service providers, lawful recipients|
For purposes of the CCPA, we do not “sell” personal information to third parties for monetary or other valuable consideration.
Rights of California Residents
California law provides California residents with the following privacy rights:
Right to access personal information: Users exercising this right may request, up to two times per year, access to the categories and specific pieces of their personal information we have collected, used, disclosed or sold in the prior 12 months.
Right to data portability: Users exercising this right may receive their personal information we have collected in the prior 12 months, when provided electronically, in a readily-usable format.
Right to deletion: Users exercising this right can ask us to delete their personal information we have collected, subject to several exceptions provided by the CCPA.
Right to disclosure: Users exercising this right can receive additional information regarding the sources from which we collect information, the purposes for which we collect and share personal information, the information of theirs we hold, and the categories of parties with whom we share their information.
Right to opt-out of sales: Although we currently do not engage in the “sale” of personal information for monetary or other valuable consideration as defined by the CCPA, you may contact us and be added to our opt-out of sale list in the event that we ever do begin the sale of personal information.
Right to be free from discrimination: Users may freely exercise these rights without fear of being denied goods or services.
Shine the Light Act: California law permits California residents to request information regarding our disclosure of your personal information to third parties for their direct marketing purposes.
Removal of Content: California residents under the age of 18 who are registered users of our service and have posted content on our services have the right to obtain removal of the content or information they have publicly posted.
If you are a California resident and would like to exercise one of your rights, please contact us at email@example.com. Please note that we may require you to verify your identity, and may require additional information from you, in order to honor your request, and there may be circumstances where we will not honor your request, as permitted under the law. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations.
|Vendor Name||Description||Location of Processing||Corporate Location|
|Google Cloud Platform||Cloud Hosting||United States||United States|
|MongoDB||Database Hosting||United States||United States|
|Stripe||Payment Processing||United States||United States|
|HubSpot||Sales and Account Management||United States||United States|
We may update this policy from time to time, and the updated version of this policy will be effective upon posting. Please check this page to review the most up-to-date version of this policy.
16. Questions / Contacting Us