Privacy Policy

Privacy Policy

Privacy Notice for California Residents

LAST UPDATED: December 19, 2019

SWYTCHBACK PRIVACYPOLICY

1. Introduction.

     This Privacy Policy applies to all the products, services, websites and apps offered by Swytchback, Inc., except where otherwise noted. We refer      to those products, services, websites and apps collectively as the “services” in this policy.

     References to “data” in this Privacy Policy will refer to whatever data you use our services to collect, whether it be survey responses, data      collected in a form, or data inserted on a site or service hosted by us – it’s all your data. Reference to personal information or just information,      means information about you personally that we collect or for which we act as custodian.

     If you want to identify your data controller please see the “Who is my data controller” section below.

2. Information we collect.

   2.1 Who are “you”?

     “You” includes …

     Creators: You hold an account within a Company service and you either directly create surveys, swydgets (our name for our surveys), interactive      marketing content, forms, applications, or questionnaires or you are collaborating on, commenting on, or reviewing surveys, forms, applications,      or questionnaires within an account.

     Respondents: You have received a survey, swydget, form, application, interactive marketing content, or questionnaire powered by our service.

     Website Visitor: You are just visiting our website.

   2.2 Information we collect about you.

     Contact Information (for example an email address).  You might provide us with your contact information, whether through use of our services,      a form on our website, an interaction with our sales or customer support team, or a response to one of our own surveys.

     Usage information.  We collect usage information about you whenever you interact with our websites and services. This includes which      webpages you visit, what you click on, when you perform those actions, what language preference you have, and so on.

     Device and browser data.  We collect information from the device and application you use to access our services. Device data mainly means      your IP address, operating system version, device type, system and performance information, and browser type. If you are on a mobile device we      may also collect the UUID for that device.

     Information from page tags.  We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect      data about visitors to our websites. This data includes usage and user statistics. Emails sent by Swytchback or by users through our services      include page tags that allow the sender to collect information about who opened those emails and clicked on links in them.

     Log Data.  Like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files      contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g.,      HTML pages, graphics, etc.), operating system versions, device type and timestamps.

     Referral information.  If you arrive at a Swytchback website from an external source (such as a link on another website or in an email), we      record information about the source that referred you to us.

     Information from third parties and integration partners.  We collect your personal information or data from third parties if you give permission      to those third parties to share your information with us or where you have made that information publicly available online.

     If you are a Creator we may also collect:

     Account Information.  You need a Swytchback account before you can use Swytchback services.  When you register for an account, we may      collect your first and last name, username, password and email address. If you choose to register by using a third party account (such as your      Google or Facebook account), please see “Information from third parties” below.

     Billing information.  If you make a payment to Swytchback, we may require you to provide your billing details, a name, address, email address      and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account      number). If you provide a billing address, we will regard that as the location of the account holder to determine which Swytchback entity with      whom you contract.

     Use of some of our services will also result in us collecting the following data on your behalf:

     Survey/form/application data.  We store your survey/form/application data (questions and responses) for you and provide analysis tools for you      to use with respect to this data.

     Profile data.  When you sign up for our services you may be asked to provide us with information about yourself and to give us more detailed      insights into who you are.

3. How we use the information we collect.‍

   3.1 Creator

     We process personal data about you either with your consent or in order to:

• Fulfill our contractual responsibility to deliver the services to you;
• To pursue our legitimate interests of:
• improving service experience; and
• developing new products and service features.

     In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing      we are relying upon.

     You have consented to us using certain types of cookies on our websites. In particular we use:

     Page tags and web beacons.

     We may collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. We may also      use page tags to allow the email sender (for a survey or form for example) to measure the performance of their email messaging and to learn      how to improve email deliverability and open rates.

     Cookies.

     We use cookie data to personalize online marketing campaigns to be relevant to you and your use of our services. By clearing your cookies in      your browser settings you will no longer see personalized messages in this way but you continue to see ads over the internet that are not based      on information you provided to us.

     We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in      this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only      the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and      messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

     Contact Information.

     We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (for as      long as you do not opt-out), as well as to contact you or to solicit you to participate in other Swytchback surveys or access other services or offers      provided by Swytchback or its clients. We may also use your email address to send you marketing (newsletters), unless you indicate a      preference to opt- out and for general updates on your account.

     How you use our services.

     We use information about how you use our services to improve our services for you and all users.

     Use data.

     We collect information about the types of surveys/forms/applications/marketing modules you create to build a profile about you so as to help           direct you to other relevant features and services we offer and help you in using our services, for example by making recommendations for you to      optimize use of our services.

     Device data.

     We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based      on your IP address.

     Device and browser data.

     We collect device and browser data to help us improve your service experience through a specific device/browser by optimizing how the website      looks in a particular browser, how your screen brightness affects your experience and to ensure the service operates optimally and as it should      on different devices and browsers.

     Log data.

     We use log data for many different business purposes to include:

•    To monitor abuse and troubleshoot;
•    To create new services, features, content or make recommendations;
•    To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
•    To fix bugs and troubleshoot product functionality.

     Your IP address is used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

     Referral information.

     We use referral information to track the success of our integrations and referral processes.

     Third parties and integrations.

     We will collect and use information from third parties and integration partners to:

•    Ensure you can sign-up to our service from a third party integration like Facebook/LinkedIn/Microsoft/Google/SSO;
•    Personalize our services for you; and
•    Ensure you can use our service in conjunction with other services.
•    Log data.

     We use log data for many different business purposes including:

•    To monitor abuse and troubleshoot;
•    To create new services, features, content or make recommendations;
•    To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
•    To fix bugs and troubleshoot product functionality.

     Your IP address may also be used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).

     Service and Marketing uses.

     We combine information about you from third party sources with information we hold about you to create a user profile, which we may use to help      us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.

     Machine learning.

     We may use machine learning techniques on certain data in order to provide users with useful statistics and more relevant insights from the data      they have collected using our services and to optimize our marketing campaigns. By way of example, if you have used open text questions in a      survey, our machine learning may provide you with useful insights into the trends in responses to that question in our analytics tools.

     Administrative Uses.

     To manage our services, we will also internally use your information and data for the following limited purposes:

•    To enforce our agreements where applicable;
•    To prevent potentially illegal activities;
•    To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing    activities, spam, and fraud; and

     Other legal uses.

     To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena      or other legal request, we may need to inspect the data we hold to determine how to respond.

     We collect and use the following data on the basis that we have to use this information in order to fulfill our contract with you:

     Your Account Information.

     We need to use your account data to run your account, provide you with services, bill you for our services, provide you with customer support,      and contact you about your service or account. We may occasionally send you communications of a transactional nature (e.g. service-related      announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You cannot opt out of these      communications since they are required to provide our services to you.

     Your Profile.

     We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing      preferences) for legitimate interests like providing you with a personalized experience and relevant and useful marketing information as well as to      make other product, feature and service recommendations to you to optimize your use of the services we offer.

     You can object to us using your data as described above but our ability to fully and properly provide our services to you may be impacted if you      do not want us to collect or use the above data.

     Your Data.

     We also use survey questions and responses on an aggregated and anonymized basis as described in this Privacy Policy, but we will never      sell individual response data or identify / contact individual respondents except on your request or where required by law. In some cases you      can avoid the use of your survey/ responses in this way by simply choosing not to use a feature or by indicating your preferences in your      account. See our “Respondent” section.

   3.2 Respondent

     We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in      this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only      the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and      messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

     Cookies (to include page tags).

     We collect information using cookies when you take a survey. These cookies are used to ensure that the full functionality of our survey service is      operational, to ensure the survey operates appropriately and optimally. After completion of a survey, in most cases, you will be re-directed to our      website and treated as a website visitor where other cookies may be used so you should read our Website Visitor section if this is of interest to      you. For example, we may use page tags to allow the email sender (for a survey or form for example) to measure the performance of email      messaging and to learn how to improve email deliverability and open rates. We also use cookies to ensure a respondent can only take a survey      once (where the Creator has set this function) and to track completion rates of surveys.

     Contact Information.

      As a Respondent, we only use contact information to respond to an inquiry which you submit to us or to solicit you to participate in other      Swytchback surveys or access other services or offers provided by Swytchback or its Clients. For example, our customer support team use your      email address to communicate with you if you have contacted us about a survey, form, application or questionnaire you received, but we will not      send marketing to you unless you have otherwise opted-in to marketing.

     How you use our services (applicable to survey Respondents only).

     We use information about how you use our services to improve our services for you and all users.  For example, we may collect information      about the types of questions you answer. This data will be aggregated and anonymized so we can examine patterns in terms of respondent      preferences when submitting responses. We collect and use all this data for our legitimate interests like helping us improve the experience for      respondents (so that questions are easier to answer), to understand industry trends in and to help improve the completion rates on      surveys/forms. We may also use usage information such as the type of survey, form, questionnaire or application that you answered to      personalize products we show you on completion of a survey when you are re-directed to our website.

     Device and browser data.

     We use device data both to troubleshoot problems with our service and to make improvements to it. We also may infer your geographic location      based on your IP address or obtain it directly if you agreed to provide it to us. For example, we collect data to ensure that service experience      works well across all possible devices and to infer geographic location to produce aggregated data around Respondent location trends. We also      want to use this information to provide an additional data layer to Creators so that they can filter responses by e.g. inferred geographic location.      Finally, we will use this information to compare and look at trends on how our service operates and how you interact with surveys, on different      browsers and devices.

     Log data.

     We use log data for many different business purposes including:

• To monitor abuse and troubleshoot;
• To create new services, features, content or make recommendations;
• To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
• To fix bugs and troubleshoot product functionality.

     Your IP address is used to ensure that you do not complete the same survey, form, application or questionnaire twice if the creator has included      settings to avoid this (ballot stuffing), for abuse monitoring purposes (so we can identify a Respondent who abused the survey taking experience      in a manner contrary to our usage policies or to facilitate the Creator in complying with their own legal obligations). We also collect log data to      collate aggregated data and metrics on activity at a non-identifying level and so that we can identify trends in survey taking over time.

     Third parties and integrations.

     We will collect and use information from third parties and integration partners to facilitate Creators in sending      surveys/forms/applications/questionnaires to you.

     Machine learning.

     We may use machine learning techniques on response data, metadata (as described above) and cookie data, in order to provide Creators with      useful and relevant insights from the data they have collected using our services, to build features, improve our services and to develop      aggregated data products. You can read more about this in relation to surveys below.

     Network monitoring.

     To manage our services we will also internally use your information and data for the following limited purposes:

•    To enforce our agreements where applicable;
•    To prevent potentially illegal activities; and
•    To screen for and prevent undesirable or abusive activity. For example, we may adopt automated systems that screen content for phishing    activities, spam, and fraud.

     Legal uses.

     To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or      other legal request, we may need to inspect the data we hold to determine how to respond.

     Use of survey responses (Swytchback surveys only).

     In general survey responses to Swytchback surveys are controlled and managed by the Creator (the person who sent or deployed that survey).      In those instances, Swytchback is only processing those responses on behalf of the Creator. Swytchback may also be a Creator when requested      by its clients to do so.

     Our goal is to improve the user experience across Swytchback services while maintaining the confidentiality and privacy of responses.  

     We use data in the ways described below, for legitimate interests pursued by us which are described in this section:

     The data impacted by this section includes:

• Survey type, question type and responses (at an aggregated and anonymized level only);
• Device data
• Log data

     We may use automated processes and machine learning, to analyze survey responses, which in turn helps us to:

     Aggregate response data and activity: We may aggregate responses, activity and behavior of Respondents so that we can identify trends, build      product features that optimize responses, make product recommendations and provide guidance on which products and services work best in      different scenarios. These product features also provide feedback and recommendations to increase response rates.

     Extract and analyze usage patterns: By understanding response data and Respondent interaction in different types of surveys we can improve      our services and ease of use, for example, we might identify when respondents prefer multiple choice versus open text questions and make      predictive response suggestions when certain question types are selected. We might also use this data to help improve analysis of responses      and/or identify insightful data trends, which never identifies any individuals.

3.3 Visitor

     We process personal data about you as a Visitor where you have either consented or we have a legitimate interest in improving service      experience and/or developing new products and service features.

     In each of the instances where we describe how we use your data in this privacy policy, we have identified which of these grounds for processing      we are relying upon.

     When you have consented, we collect and use the following information about you:

     Contact Information.

     We use contact information to respond to your inquiries, send you information as part of the services, and send you marketing information (as      long as you have agreed to this at the point of providing your information and for as long as you do not opt-out), or to solicit you to participate in      other Swytchback surveys or access other services or offers provided by Swytchback or its Clients.

     For example, we provide your email address to a member of our sales team who will contact you if you submitted an inquiry through one of the      online forms on our site. You will also receive marketing communications from us if you have consented to this at the point where you provided      your information.

     Cookies – page tags and web beacons.

     We may collect information from page tags and web beacons to allow us to determine the success of our advertising campaigns. We also use      page tags to allow the email sender (for a survey or form for example) to measure the performance of their email messaging and to learn how to      improve email deliverability and open rates.

     How you use our services.

     We use information about how you have interacted with our websites to improve our website services for you and all users. For example, we      collect information about the webpages you have visited and your activity on our sites. We collect this information so that we can track the most      visited and most useful parts of our website to identify what are our most popular services.

     As a result of the above data we collect, we also combine information about you from third party sources with information we hold about you to      create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve our     marketing campaigns and website experience.

     Machine learning.

     We use machine learning techniques on certain data in order to optimize our marketing campaigns.

     We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in      this privacy policy. We have undertaken to ensure that we place clear limitations on each of these uses so that your privacy is respected and only      the information necessary to achieve these legitimate aims is used. Our primary goal is to improve upon and make sure our services and      messaging are relevant for all our users, while also ensuring that personal information of all users is respected and protected.

     Device data.

     We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer your geographic location based      on your IP address. For example, we collect device and browser information from you to troubleshoot website functionality issues and to fix bugs.

     Log data.

     We use log data for many different business purposes to include:

• To monitor abuse and troubleshoot;
• To track your preferences and create new services, features, content or make recommendations personalized for you;
• To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services; and
• To fix bugs and troubleshoot product functionality.

     For example, we capture your browser type to determine how we can present our website best within that browser environment.

     Referral information.

     We use referral information to track the success of our integrations and referral processes.  To manage our services we will also internally use      your information and data, for the following limited purposes:

• To enforce our agreements where applicable;
• To prevent potentially illegal activities;
• To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content or phishing activities, spam, and fraud; and‍

     Legal uses.

     To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or      other legal request, we may need to inspect the data we hold to determine how to respond.

4. Information you share

     Our services may let you share information with others. Remember that when you share information publicly, it can be indexable by search      engines. Our services provide you with different options on sharing and deleting your content but we cannot delete content from search engines      so you need to be careful about information you make public.

5. Information we share: Partners and Integrations

     We do not share your information or data with third parties outside Swytchback except in the following limited circumstances: 

• If you are a Creator that is part of an Enterprise team using Swytchback, your account information and data will be shared with the primary administrator(s) and your survey data may also be visible to other members in your team with whom you share your surveys or with whom you collaborate.
• To help us provide certain aspects of our services we may use our affiliates and trusted key partners – in particular, we engage third parties to facilitate our email collectors for sending surveys by email to Respondents, facilitate customers in making credit card payments, deliver and help us track our marketing and advertising content, help us track website conversion success metrics, and manage our sales and customer support services to you.

     We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in      privacy and security standards.  On your instructions, we share your information or data if you choose to use an integration in conjunction with      our services, to the extent necessary to facilitate that use.

     We also have to share information or data in order to:

•  meet any applicable law, regulation, legal process or enforceable governmental request;
•  enforce applicable policies, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues; and
•  protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.

6. Cookies.

     We and our partners use cookies and similar technologies on our websites.

     We use certain cookies that you agree to when you use our sites and, in the case of some cookies, for legitimate interests of delivering and      optimizing our services (where the cookie delivers essential functionality). Cookies are small bits of data we store on the device you use to      access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We      use cookies and similar technologies for several reasons:

• To gather metrics about your survey taking experience.  For example, we will collect data about the number of clicks it took Respondents to complete a survey, whether they left and returned to a survey, whether they skipped parts of a survey and how long it took to complete the survey and other details about the survey taking.
• To make our site easier to use.  As an example, for Creators if you use the “Remember me” feature when you sign into your account, we store your user name in a cookie to make it quicker for you to sign in whenever you return to Swytchback.
• For security reasons. For example we use cookies to authenticate your identity and confirm whether you are currently logged into Swytchback or determine if an incident impacts you.
• To provide you with personalized content. For instance we store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can personalize the content you see.
• To improve our services. For instance, we use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimize the content we display to you (which may include marketing content).
• To advertise to you. For instance we, or our service providers and other third parties we work with, may place cookies when you visit our website and other websites or when you open emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, we evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive ads that are tailored to you based on your online activity, you may “opt out” of many of the companies that are involved in such tailoring by going to https://www.aboutads.info, https://preferences-mgr.truste.com/ or, if you’re located in the European Union, at https://www.youronlinechoices.eu. Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.
• Google Analytics.  In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

     You can choose to remove or disable cookies via your browser settings.

7. Data Retention.

     If you hold an account with Swytchback we do not delete the data in your account – you are responsible for and control the time periods for which      you retain this data. There are controls in your account where you can delete data at the account level (all data in your account) and at the      response level. If you are a Respondent, you will need to ask the Creator how long your responses will be stored in Swytchback services.

8. Safety of Minors.

     Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of 13 (or under a higher age if permitted      by the laws of their residence). Swytchback does not knowingly collect personal data from Minors or allow them to register. If it comes to our      attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this      has occurred, please contact customer support.

9. Privacy Shield (relevant to our EU users).

     EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield.

     We have entered into contractual terms to include standard contractual clauses for the transfer of Swytchback data as part of delivery of service.

     Swytchback, Inc. is located in the United States and, accordingly, data (including Respondent data) will be transferred to the United States.

     We participate in and have certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal      information and data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s      applicable Principles.  For purposes of the Privacy Shield Framework, we define “personal information” as data about and identified or identifiable      individual that is received by us from individuals in the European Union and recorded in any form.  To learn more about the Privacy Shield      Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/.

     We also comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward      transfer liability provisions.

     When we receive personal information under the Privacy Shield and then transfer it to a third-party service provider acting as agent on our behalf,      we have certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield      and (ii) we are responsible for the event giving rise to the damage. With respect to personal data received or transferred pursuant to the Privacy      Shield Framework, we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.  In certain situations, we      may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law      enforcement requirements.

     Please contact Swytchback as described in Section 13 below if you have any concerns or complaints of any nature.

     Under certain conditions, more fully described on the Privacy Shield website

     https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution      procedures have been exhausted.

     In compliance with Privacy Shield Principles, Swytchback commits to resolve complaints about our collection or use of your personal information.      EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should contact Swytchback at info@swytchback.com.

     If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third party      dispute resolution provider (free of charge), at https://www.jamsadr.com/eu-us-privacy-shield.

10. Changes to our privacy policy.

     We can make changes to this Privacy Policy from time to time. We will identify the changes we have made on this page. In circumstances where      a change will materially change the way in which we collect or use your personal information or data, we will send a notice of this change to all of      our account holders.

11. Personalized marketing.

     We provide opt-out options in all direct marketing emails. If you do not wish to see personalized marketing content on the web related to our      service you can clear the cookies in your browser settings.

12. Who is my data controller?

     As mentioned above – all response data at an individual level is controlled by the Creator. Swytchback can be a data controller of data about      Respondents if we are the creator of the survey, including on behalf of a client or partner of Swytchback, or a user of Swytchback (including you      as an author) can be the Data Controller.

13. Your rights.

     Some of you (in particular, European users and those whose information we receive under the EU-U.S. Privacy Shield) have certain legal rights      to obtain information about whether we hold personal information about them, to access personal information we hold about them, and to obtain      its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or      limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a      request).

     Rights which you are entitled to are:

• Data access rights;
• Right to restrict processing;
• Right of Rectification;
• Right to Erasure (Right to be Forgotten);
• Right to object to processing;
• Right to withdraw consent; and;
• Data portability rights.

14. Exercising your rights.

     Our Contact Information for Privacy Inquiries