Last revised on December 1, 2022

At Collecteurs, our priority is our Members. We respect the privacy of Your information and Your collection. We will never sell Your personal information or collection information to Third Parties.

Our Privacy tools keep You in charge of Your collection and data. Our values are part of every decision we make, including how we gather and respect your personal information and choose which offers and services to present to you.

We’ve created the policy below to be as transparent and straightforward as possible.

Collecteurs is the first crowdsourced digital museum dedicated to bringing the world’s private collections out of the dark.

Collecteurs was designed to help collectors digitize, manage, grow, and exhibit their collections to global audiences. Collectors can also collaborate and interact with one another. Collecteurs helps Gallery members to manage inventory, create exhibitions, sell artworks, connect & interact with collectors and get editorial coverage. Collecteurs also helps artists digitize, manage, sell, and share their artworks with global audiences. Collectively, the “Service” and “Services.”

Our Registered Users, Galleries and Members (“Users”) share their identities, engage with our network, catalogue their collection, share artworks, buy and sell artworks, buy and sell DABs and PABs, post and view relevant content (“Content”). Some content on our Services is also visible to unregistered viewers (“Visitors”) and the general public.

Content, including your name, city, and artworks that are visible to the public can be visible to search engines, unregistered viewers (“Visitors”), and Registered Users. We may share your name, city, basic information and publicly-shared artworks on social media and in marketing communications with other Members, Galleries, Visitors, and the public if you have made the information public on our platform.

We may share your information with your consent or as required by law.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties: (a) with your consent; (b) where it is necessary to carry out your instructions; (c) as is reasonably necessary in order to provide our features and functionality to you; (d) when we reasonably believe it is required by law, subpoena or other legal process; (e) as necessary to enforce our User Agreement or protect the rights, property, or safety of Collecteurs, our Members and Visitors, and the public. We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

This Privacy Policy applies to Collecteurs, the Collecteurs mobile application, and Collecteurs Magazine. We may modify this Privacy Policy from time to time, and if we make significant material changes to it, we will provide notice through our Service, or by other means so that you may review the changes before you continue to use our Services. If you object to any changes, you may close your account. Continuing to use our Services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

Our Privacy Policy applies to any Member, Gallery Member, Artist Member, Registered User, or Visitor.

We collect information when you use our Services to store your collection records and offer you a personalized and relevant experience, including growing your network, discovering new collectors, collections, artworks, galleries, artists, and access to opportunities in our platform. We may also use your data to create new products, services and offerings. If you have any concern about providing information to us or having such information displayed on our Services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a Member or Registered User, visit our websites, apps or otherwise use our Services. If you have already registered, you can delete your account.

We collect your personal information in the following ways:

Registration

When you create an account with us, we collect information (including your name, email address, the city you reside in, and password).

To create an account on Collecteurs, you must provide us with your real name, a profile picture, email address, the city you reside in, security questions and a password and agree to our Terms of Use and this Privacy Policy, which governs how we treat your information. You may provide additional information during the registration process (for example, billing address, credit card details, your job, institutions and companies you are affiliated with) to help you build your profile. You understand that, by creating an account, we and others will be able to identify you by your Collecteurs profile.

Profile Information

We collect information when you fill out a profile. Your name and profile image are public by default. You can list institution or company affiliations, board memberships, professional affiliations and other information. Subject to the settings you choose, your artworks may be visible to others. The Privacy Settings are on an artwork-by-artwork basis. If you choose to turn your artwork Privacy Settings to Public then all artworks that you have set to Public will be visible to Members, Registered Users, Visitors, and the Public. In addition, any Posts that you share on your feed have their own Privacy Settings and can be set to Community or Public. If you choose to turn your Post’s Privacy Setting to Public then all content you have shared on that Post will be visible to Members, Registered Users, Visitors, and the Public. Do not provide personal information or artworks you would not want to be public. We may use and share information you provide in accordance with this Privacy Policy and our Terms of Use.

Invitations and Other Services

Please note that when you send an invitation to join our Service, to follow or connect with someone (a “connection”), or to participate in our Services that person may have access to your name and profile information.

We make other tools available to sync information with our Services and Message Center and may also develop additional features that allow Members to use their account in conjunction with other third-party services.

Any information that you upload or sync with our Services is covered by this Privacy Policy. You can remove or deactivate your information at your convenience using the features we make available.

Interactions

When you take a social action (such as liking, commenting on, or sharing a post) we will associate you with the content and your Followers, other Members and Users may be able to see this action on the artwork or in their notifications bar. When you like or comment on an artwork, Visitors and the Public may be able to see this content.

Buying and Selling Artworks (PABs and DABs)

If you are a registered user and place orders through the Site, we may collect your purchase history, billing address, phone number, email address, digital wallet address and type, and other digital contact information.

Public Information Derived from Blockchains

We may collect data that is publicly available on blockchains. This may include blockchain addresses, purchase information, sales and/or transfers of non-fungible tokens (“NFTs”).

Requesting an Invitation Form

We collect the Personal Information you voluntarily provide when you complete a request for an invitation to the Site. For example, if you choose to request an invitation for an invitation-only account type, we collect the information you provide in the application form.

Subscribe to Email List

If you subscribe to our mailing list, we collect your name, address, and email address.

Customer Service

We collect information when you contact us for customer support.

When you contact our customer support services (e.g. on our Knowledge Base/Support Page), we have to access messages, artworks, posts, reminders, backrooms, contacts, and other contributions to our Services. We do not retain your credit card information, but you may provide it to us at time of customer support inquiry in order to resolve your card-related issue. We collect the information we need to categorize your question, respond to it, and, if applicable, investigate any breach of our Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you and protect the privacy and security of our Users.

Cookies

Like many companies, we use cookies and similar technologies, including browser and mobile application identifiers, to collect information in order to help us recognize you, learn about your interests both on and off our Services, improve your experience, increase security, measure use and effectiveness of our Services, and serve advertising. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor. We use third-party cookies set by our service provider, Google Analytics, to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site. You can control cookies through your browser settings and other tools. By using or visiting our Services, you consent to the placement of cookies and beacons in your browser and/or on your mobile device and HTML-based emails in accordance with this Privacy Policy.

You can visit https://www.google.com/analytics/learn/privacy.html to learn more about Google Analytics’ use of cookies. You can visit https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

Advertising Technologies and Web Beacons

We use advertising technologies and web beacons to collect information. By using our site, you consent to our use of beacons and other advertising technologies. We target (and measure the performance of) ads to Members, Registered Users, and Visitors and others both on and off of our Services through a variety of ad networks and ad exchanges, using the following, whether separately or combined:

Your use of our Services (for example, your search history, the content you viewed on Collecteurs, which pages you visit, etc.); Information from 3rd parties (e.g. advertising partners, publishers and data aggregators) which we use in addition to the information from our cookies (and similar technologies), your profile and use of our Services.

We do not share your personal information with any third-party advertisers or ad networks for advertising without your separate permission. Note that, as described in Section B.6, your profile picture, name, and the city you reside in are visible to other Members, Users, Visitors, and through public search. Also, advertising partners may associate personal information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we contractually require such advertisers to obtain your explicit opt-in consent before doing so.

We may show you sponsored content, which will be designated as sponsored content and will behave like other updates. If you take social action (for example, if you click on like button (blue heart) or comment on the sponsored content), your action may be seen by your network and by the connections and followers of your connections and followers and other Members who are shown the sponsored content after you have acted on it in addition to the sponsor of the content.

Log Files, IP Addresses, and Information About Your Computer and Mobile Device

We collect information from the devices and networks that you use to access our Services. When you visit or leave our Services (whether as a Member, User, or Visitor) by clicking a hyperlink or when you view a third-party site that includes our plugin or cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers receive the URL of the page that you are on when you click an ad on or through our Services. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, time of your login, your IP address location, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing Collecteurs using a mobile device), and the name of your ISP or your mobile carrier. We also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile applications and for fraud prevention and security purposes. We will honor the privacy setting you have selected on your mobile devices, including real-time location data collection.

Other

We are constantly innovating to improve our Services, which means we may create new ways to collect information on the Services. Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information and we may combine this information collected about you. We treat the combined information in accordance with this Notice. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information. If we start collecting substantially new types of personal information and materially change how we handle your data, we will modify this Privacy Policy and notify you.

Consent to Collecteurs Processing Information About You

You agree that information you provide on your profile can be seen by others and used by us as described in this Privacy Policy and our Terms of Use. The personal information that you share or provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile. By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our Terms of Use and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part.

To Provide the Services and Enhance Your Experience

We use information about you to provide the Services to you, including to process payment transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. We are always looking for ways to make our Services smarter, faster, more secure, integrated and useful to you. It is in our legitimate business interests to continue to maintain and improve Services. To that end, we use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.

To Communicate With You

We may send you messages relating to the availability of the Services, security, or other service-related issues. We may also send promotional messages to your inbox. You can change your email settings at any time. We communicate with you through email, notices posted on the Collecteurs website or apps, messages to your Collecteurs inbox, and other means available through the Services, including mobile text messages and push notifications, as well as on platforms like Facebook and Google. Examples of these communications include: (1) welcome and engagement communications – informing you about how to best use our Services, new features, updates about other Members you are connected to and their actions, etc.; (2) service communications – these will cover service availability, security, and other issues about the functioning of our Services; (3) promotional communications – these include both email and Collecteurs messages, and may contain promotional information directly or on behalf of our partners. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, events and other information we think may be of interest to you. We also communicate with you about new product offers, promotions and contests. These messages will be sent to you based on your profile information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your Collecteurs email settings.

For Safety and Security

We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.

To Protect Our Legitimate Business Interests and Legal Rights

Where required by law, where we believe it is in our legitimate business interest, or where it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

With Your Consent

We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

Additional Purposes

We may process your information for any other purpose disclosed to you in connection with our Services from time to time. If we intend to process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing and will obtain your consent where necessary.

Legal Basis for Processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where: we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; you give us consent to do so for a specific purpose; or we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Sharing Internally

We may share your personal information with entities controlled by Collecteurs. You are consenting to this sharing.

Sharing with Other Users

With certain communications you send on our Services, the recipient can see your name, email address, and certain network information. Many communications that you initiate through our Services (for example, an invitation sent to a non-Member, a purchase request in our Marketplace) will list your name, profile image, and primary email address in the header of the message. Once you have connected with an individual, regardless of who sent the invitation, your contact information will be shared with that individual.

Our Services help you search for other collectors, collections, galleries, institutions, curators, artists, posts, hashtags as well as artworks. Your name, collection, or artworks may appear in searches performed by other Members, Registered Users, or Visitors. Your artwork Privacy Settings will determine what artwork information searchers see and how they see it.

Sharing Information with Third Parties

Your name, profile picture, city that you reside in, and collection name are publicly visible. Any artwork or post you make visible to the public (PUBLIC ON Setting) on Collecteurs will be visible in search engine results and to the public in general. The information shown to others is limited and does not include all information. The fields visible to others are clearly indicated when you are adding artworks. We do not provide any of your non-public information (like your email address) to third parties without your consent, unless required by law.

The visibility of your artworks and collection boards to other Members depends on your degree of connection with the viewing Member (e.g. settings Private ON/OFF / Community ON/OFF / Public ON/OFF) or Anonymous ON/OFF).

For marketing purposes, Collecteurs may share images of artworks which the Member has shared with the public (Public ON). We could share these works within Collecteurs’ network as well as on Third Party websites such as Instagram, TikTok, Facebook, Twitter and through email communications with our Members, Users, and Mailing List subscribers. Information shared may include the artwork image, artist name, title, year, Collecteurs member name, collection name, and city you reside in. No User-identifying information beyond the profile image, member name, collection name, and city you reside in may be shared. Artworks that are set to Community ON may be shared through email communications with our members. Artworks that are set to Private ON will not be shared.

We do not rent or sell personal information that you have not posted on our Services, except as described in this Privacy Policy. We will not disclose personal information that is not published to your profile or generated through engagement with our other services except to carry out your instructions (for example, to process payment information) or unless we have your separate consent, unless we have a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our User Agreement; (3) respond to claims of a violation of the rights of third parties; (4) respond to Member service inquiries; or (5) protect the rights, property, or safety of Collecteurs, our Services, our Members, Registered Users, Visitors, or the public.

We may disclose your personal information if compelled by law, subpoena, or other legal process, or if necessary to enforce our User Agreement. It is possible that we may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required by law, subpoena, or other legal process, whether in the United States or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of Collecteurs, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand. To find out more about how we engage with government requests for data see our Law Enforcement Data Request Guidelines.

Third parties (for example, your email provider) may give you the option to upload certain information in your contacts stored with us onto their own service. If you choose to share your contacts in this way, you will be granting your third party provider the right to store, access, disclose and use these contacts in the ways described in such third party’s terms and privacy policy.

Sharing with App Developers

We work with developers to build Platform Applications using our developer tools. Whether you use Platform Applications is up to you. If you have given a Platform Application access to your Collecteurs account, you can revoke that permission anytime. Also, you can opt out of providing information to developers through your connections. We collaborate with and allow third parties to use our developer platform to offer services and functionality in conjunction with our Services. These third-party developers have either negotiated an agreement to use our platform technology or have agreed to our self-service API and Plugin terms in order to build applications (“Platform Applications”). Both the negotiated agreements and our API and Plugin terms contain restrictions on how third parties may access, store, and use the personal information you provide to us.

Sharing with Successors

If there is a change in control or sale of all or part of Collecteurs, we may share your information with a third party, who will have the right to use that information in line with this Privacy Policy. We may also disclose your personal information to a third party as part of a sale of the assets of Collecteurs Corporation, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

Sharing with Service Providers

We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.

Sharing with Law Enforcement

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect us, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

We Do Not Share with Direct Marketers

We do not share any of your personal information with third parties for direct marketing. California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

Keeping your information secure is a top priority for us. To that end we comply with industry-standard best practices to secure your information. We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account Information

We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Information You Share on the Services

If your account is deactivated or disabled, some of your information and the content you have provided will remain.

Marketing information

If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Access and Update Your Information

Our Services and related documentation give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

Deactivate Membership

You can deactivate your access to the Services in the Settings section of the Site.

Delete Your Information

Our Services and related documentation give you the ability to delete certain information about you from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

Request That We Stop Using Your Information

In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.

Opt Out of Communications

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.

Send “Do Not Track” Signals

Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Social Media Plug-Ins

We may use social media plug-ins from social media networks like Facebook, Pinterest, Instagram, YouTube, TikTok and Twitter, which will be labeled on our Site with the well-known symbols of the respective social network. If you interact with these plug-ins, your activity on the Site may also be made available to those social networks. In order to understand how those social networks use and disclose your Personal Information, please review the privacy policies available on the websites of those social networks.

Interest-Based Advertising

We may enable Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and integrated services that allow Google Analytics to use cookies, device identifiers, and other tracking mechanisms to collect data for advertising purposes and to market our products and services to you through advertisements on other websites based on your past interactions with our Site. You can opt out of Google remarketing by downloading and installing Google’s opt-out browser add-on. Alternatively, for participating ad networks, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.

On-Chain Data

By using the Site, you acknowledge that your Personal Information, including your wallet address, is stored on the applicable publicly searchable blockchain and that neither the Site nor any third party has the power to delete such data published by its Users to the blockchain. The Site is not capable of modifying or deleting data that is stored on the blockchain. The details of your NFT transactions, including your history of purchases and sales of DABs and PABs, are public information and stored on the blockchain and associated with your wallet address.

Data portability

Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control.

We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

International Transfers to Third Parties: Some of the third parties which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer. Please see our Privacy Shield Notice below.

Privacy Shield Notice

We participate in and comply with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and the Privacy Shield Principles regarding the collection, use, and retention of information about you that is transferred from the European Union or Switzerland (as applicable) to the U.S. We ensure that the Privacy Shield Principles apply to all information about you that is subject to this privacy policy and is received from the European Union, the European Economic Area, and Switzerland.

Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

We encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us.