Cinder
PRIVACY NOTICE
Last updated December 10, 2020
Thank you for choosing to be part of our community at
Poorground LLC contact@getcinder.com .
When you
https://getcinder.com
(the "Website"),
This privacy notice applies to all information collected through
our Services (which, as described above, includes our
Please read this privacy notice carefully as it will help you
understand what we do with the information that we
collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us.
We collect personal information that you voluntarily provide to us
when you
The personal information that we collect depends on the context of
your interactions with us and the
Personal Information Provided by You. We collect
names ; email addresses ; debit/credit card numbers ;
Payment Data. We may collect data necessary to
process your payment if you make purchases, such as your payment
instrument number (such as a credit card number), and the security
code associated with your payment instrument. All payment data is
stored byStripe https://stripe.com/privacy
All personal information that you provide to us must be true,
complete and accurate, and you must notify us of any changes to such
personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP)
address and/or browser and device characteristics — is
collected automatically when you visit our
We automatically collect certain information when you visit, use or
navigate the
Like many businesses, we also collect information through cookies
and similar technologies.
The information we collect includes:
-
Log and Usage Data. Log and usage data is
service-related, diagnostic, usage and performance information our
servers automatically collect when you access or use our
Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
-
Device Data. We collect device data such as information
about your computer, phone, tablet or other device you use to
access the
Website . Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
-
Location Data. We collect location data such as
information about your device's location, which can be either
precise or imprecise. How much information we collect depends on
the type and settings of the device you use to access the
Website . For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our
contract with you, compliance with our legal obligations,
and/or your consent.
We use personal information collected via our
We use the information we collect or receive:
-
To facilitate account creation and logon process.
If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the
information you allowed us to collect from those third parties to
facilitate account creation and logon process for the performance
of the contract.
-
To post testimonials. We post testimonials on
our
Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at contact@getcinder.com and be sure to include your name, testimonial location, and contact information.
-
Request feedback. We may use your
information to request feedback and to contact you about your use
of our
Website .
-
To enable user-to-user communications. We may
use your information in order to enable user-to-user
communications with each user's consent.
-
To manage user accounts. We may use your
information for the purposes of managing our account and keeping
it in working order.
-
To send administrative information to you. We may use your personal information to send you product, service
and new feature information and/or information about changes to
our terms, conditions, and policies.
-
To protect our Services. We may use your
information as part of our efforts to keep our
Website safe and secure (for example, for fraud monitoring and prevention).
-
To enforce our terms, conditions and policies for business
purposes, to comply with legal and regulatory requirements or in
connection with our contract.
-
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to
inspect the data we hold to determine how to respond.
-
Fulfill and manage your orders. We may
use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the
Website .
-
Administer prize draws and competitions. We
may use your information to administer prize draws and
competitions when you elect to participate in our
competitions.
-
To deliver and facilitate delivery of services to the
user.
We may use your information to provide you with the requested
service.
-
To respond to user inquiries/offer support to users.
We may use your information to respond to your inquiries and
solve any potential issues you might have with the use of our
Services.
In Short: We only share information with your consent, to
comply with laws, to provide you with services, to protect
your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the
following legal basis:
-
Consent: We may process your data if you
have given us specific consent to use your personal
information for a specific purpose.
-
Legitimate Interests: We may process your
data when it is reasonably necessary to achieve our
legitimate business interests.
-
Performance of a Contract: Where we have
entered into a contract with you, we may process your
personal information to fulfill the terms of our
contract.
-
Legal Obligations: We may disclose your
information where we are legally required to do so in order
to comply with applicable law, governmental requests, a
judicial proceeding, court order, or legal process, such as
in response to a court order or a subpoena (including in
response to public authorities to meet national security or
law enforcement requirements).
-
Vital Interests: We may disclose your
information where we believe it is necessary to investigate,
prevent, or take action regarding potential violations of
our policies, suspected fraud, situations involving
potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are
involved.
More specifically, we may need to process your data or share
your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
-
Vendors, Consultants and Other Third-Party Service
Providers.
We may share your data with third-party vendors, service
providers, contractors or agents who perform services for us
or on our behalf and require access to such information to
do that work. Examples include: payment processing, data
analysis, email delivery, hosting services, customer service
and marketing efforts. We may allow selected third parties
to use tracking technology on the
Website , which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
In Short: We only share information with the
following third parties.
We only share and disclose your information with
the following third parties. We have categorized
each party so that you may be easily understand the
purpose of our data collection and processing
practices. If we have processed your data based on
your consent and you wish to revoke your consent,
please contact us using the contact details provided
in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
- Advertising, Direct Marketing, and Lead Generation
- Cloud Computing Services
- Invoice and Billing
- Retargeting Platforms
- Web and Mobile Analytics
In Short: We may use cookies and other tracking
technologies to collect and store your
information.
We may use cookies and similar tracking
technologies (like web beacons and pixels) to access
or store information. Specific information about how
we use such technologies and how you can refuse
certain cookies is set out in our Cookie Notice
6. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We keep your information for as long as
necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by
law.
We will only keep your personal information for as
long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention
period is required or permitted by law (such as tax,
accounting or other legal requirements). No purpose
in this notice will require us keeping your personal
information for longer than
one (1) months past the
start of idle period of the user's account
When we have no ongoing legitimate business need to
process your personal information, we will either
delete or anonymize such information, or, if this is
not possible (for example, because your personal
information has been stored in backup archives),
then we will securely store your personal
information and isolate it from any further
processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION
SAFE?
In Short: We aim to protect your personal information
through a system of organizational and technical
security measures.
We have implemented appropriate technical and
organizational security measures designed to protect
the security of any personal information we process.
However, despite our safeguards and efforts to
secure your information, no electronic transmission
over the Internet or information storage technology
can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able
to defeat our security, and improperly collect,
access, steal, or modify your information. Although
we will do our best to protect your personal
information, transmission of personal information to
and from our
8. DO WE COLLECT INFORMATION FROM
MINORS?
In Short: We do not knowingly collect data from or
market to children under 18 years of age.
We do not knowingly solicit data from or market to
children under 18 years of age. By using the
contact@getcinder.com
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:
In some regions (like the European Economic Area),
you have certain rights under applicable data
protection laws. These may include the right (i) to
request access and obtain a copy of your personal
information, (ii) to request rectification or
erasure; (iii) to restrict the processing of your
personal information; and (iv) if applicable, to
data portability. In certain circumstances, you may
also have the right to object to the processing of
your personal information. To make such a request,
please use the
contact details
provided below. We will consider and act upon any
request in accordance with applicable data
protection laws.
If we are relying on your consent to process your
personal information, you have the right to withdraw
your consent at any time. Please note however that
this will not affect the lawfulness of the
processing before its withdrawal, nor will it affect
the processing of your personal information
conducted in reliance on lawful processing grounds
other than consent.
If you are a resident in the European Economic Area
and you believe we are unlawfully processing your
personal information, you also have the right to
complain to your local data protection supervisory
authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact
details for the data protection authorities are
available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your
privacy rights, you may email us at
contact@getcinder.com .
Account Information
If you would at any time like to review or
change the information in your account or
terminate your account, you can:
-
Contact us using the contact information provided.
Upon your request to terminate your account, we
will deactivate or delete your account and
information from our active databases. However, we
may retain some information in our files to
prevent fraud, troubleshoot problems, assist with
any investigations, enforce our Terms of Use
and/or comply with applicable legal
requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to
set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject
cookies, this could affect certain features or
services of our
Opting out of email marketing:
You can unsubscribe from our marketing email list at
any time by clicking on the unsubscribe link in the
emails that we send or by contacting us using the
details provided below. You will then be removed
from the marketing email list — however, we may
still communicate with you, for example to send you
service-related emails that are necessary for the
administration and use of your account, to respond
to service requests, or for other non-marketing
purposes. To otherwise opt-out, you may:
-
Contact us using the contact information provided.
10. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile operating systems
and mobile applications include a Do-Not-Track
("DNT") feature or setting you can activate to
signal your privacy preference not to have data
about your online browsing activities monitored and
collected. At this stage no uniform technology
standard for recognizing and implementing DNT
signals has been finalized. As such, we do not
currently respond to DNT browser signals or any
other mechanism that automatically communicates your
choice not to be tracked online. If a standard for
online tracking is adopted that we must follow in
the future, we will inform you about that practice
in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California,
you are granted specific rights regarding access
to your personal information.
California Civil Code Section 1798.83, also known
as the "Shine The Light" law, permits our users who
are California residents to request and obtain from
us, once a year and free of charge, information
about categories of personal information (if any) we
disclosed to third parties for direct marketing
purposes and the names and addresses of all third
parties with which we shared personal information in
the immediately preceding calendar year. If you are
a California resident and would like to make such a
request, please submit your request in writing to us
using the contact information provided below.
If you are under 18 years of age, reside in
California, and have a registered account with
CCPA Privacy Notice
The California Code of Regulations defines
a "resident" as:
(1) every individual who is in the State of
California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State
of California who is outside the State of California
for a temporary or transitory purpose
All other individuals are defined as
"non-residents."
If this definition of "resident" applies to you, we
must adhere to certain rights and obligations
regarding your personal information.
What categories of personal information do we
collect?
We have collected the following categories of
personal information in the past twelve (12)
months:
|
Category |
Examples |
Collected |
|
A. Identifiers
|
Contact details, such as real name, alias,
postal address, telephone or mobile contact
number, unique personal identifier, online
identifier, Internet Protocol address, email
address and account name
|
|
|
B. Personal information categories listed
in the California Customer Records
statute
|
Name, contact information, education,
employment, employment history and financial
information
|
YES
|
|
C. Protected classification characteristics
under California or federal law
|
Gender and date of birth
|
|
|
D. Commercial information
|
Transaction information, purchase history,
financial details and payment
information
|
|
|
E. Biometric information
|
Fingerprints and voiceprints
|
|
|
F. Internet or other similar network
activity
|
Browsing history, search history, online
behavior, interest data, and interactions
with our and other websites, applications,
systems and advertisements
|
|
|
G. Geolocation data
|
Device location
|
|
|
H. Audio, electronic, visual, thermal,
olfactory, or similar information
|
Images and audio, video or call recordings
created in connection with our business
activities
|
|
|
I. Professional or employment-related
information
|
Business contact details in order to
provide you our services at a business
level, job title as well as work history and
professional qualifications if you apply for
a job with us
|
|
|
J. Education Information
|
Student records and directory
information
|
|
|
K. Inferences drawn from other personal
information
|
Inferences drawn from any of the collected
personal information listed above to create
a profile or summary about, for example, an
individual’s preferences and
characteristics
|
|
We may also collect other personal information
outside of these categories instances where you
interact with us in-person, online, or by phone or
mail in the context of:
-
Receiving help through our customer support
channels;
-
Participation in customer surveys or contests;
and
-
Facilitation in the delivery of our Services and
to respond to your inquiries.
How do we use and share your personal
information?
-
Targeting cookies/Marketing cookies
-
Beacons/Pixels/Tags
More information about our data
collection and sharing practices can be
found in this privacy notice
You may contact us
contact@getcinder.com ,
If you are using an authorized agent to
exercise your right to opt-out we may deny
a request if the authorized agent does not
submit proof that they have been validly
authorized to act on your behalf.
Will your information be shared with
anyone else?
We may disclose your personal information
with our service providers pursuant to a
written contract between us and each
service provider. Each service provider is
a for-profit entity that processes the
information on our behalf.
The current list of our service providers
can be found in below.
We may use your personal information for
our own business purposes, such as for
undertaking internal research for
technological development and
demonstration. This is not considered to
be "selling" of your personal data.
-
Category A. Identifiers, such as
contact details, like your real
name, alias, postal address,
telephone or mobile contact number,
unique personal identifier, online
identifier, Internet Protocol
address, email address and account
name.
-
Category B. Personal information,
as defined in the California
Customer Records law, such as your
name, contact information,
education, employment, employment
history and financial
information.
-
Category D. Commercial information,
such as transaction information,
purchase history, financial details
and payment information.
-
Category F. Internet or other
electronic network activity
information, such as browsing
history, search history, online
behavior, interest data, and
interactions with our and other
websites, applications, systems and
advertisements.
-
Category G. Geolocation data, such as
device location.
The categories of third
parties to whom we disclosed
personal information for a
business or commercial purpose
can be found under "WHO WILL YOUR
INFORMATION BE SHARED
WITH?".
Your rights with respect to
your personal data
Right to request deletion
of the data - Request to
delete
You can ask for the deletion
of your personal information.
If you ask us to delete your
personal information, we will
respect your request and
delete your personal
information, subject to
certain exceptions provided by
law, such as (but not limited
to) the exercise by another
consumer of his or her right
to free speech, our compliance
requirements resulting from a
legal obligation or any
processing that may be
required to protect against
illegal activities.
Right to be informed -
Request to know
Depending on the
circumstances, you have a
right to know:
-
whether we collect and use
your personal
information;
-
the categories of personal
information that we
collect;
-
the purposes for which the
collected personal
information is used;
-
whether we sell your
personal information to
third parties;
-
the categories of personal
information that we sold or
disclosed for a business
purpose;
-
the categories of third
parties to whom the personal
information was sold or
disclosed for a business
purpose; and
-
the business or commercial
purpose for collecting or
selling personal
information.
In accordance with applicable
law, we are not obligated to
provide or delete consumer
information that is
de-identified in response to a
consumer request or to
re-identify individual data to
verify a consumer
request.
Right to Non-Discrimination
for the Exercise of a
Consumer’s Privacy Rights
We will not discriminate
against you if you exercise
your privacy rights.
Verification process
Upon receiving your request,
we will need to verify your
identity to determine you are
the same person about whom we
have the information in our
system. These verification
efforts require us to ask you
to provide information so that
we can match it with
information you have
previously provided us. For
instance, depending on the
type of request you submit, we
may ask you to provide certain
information so that we can
match the information you
provide with the information
we already have on file, or we
may contact you through a
communication method (e.g.
phone or email) that you have
previously provided to us. We
may also use other
verification methods as the
circumstances dictate.
We will only use personal
information provided in your
request to verify your
identity or authority to make
the request. To the extent
possible, we will avoid
requesting additional
information from you for the
purposes of verification. If,
however, if we cannot verify
your identity from the
information already maintained
by us, we may request that you
provide additional information
for the purposes of verifying
your identity, and for
security or fraud-prevention
purposes. We will delete such
additionally provided
information as soon as we
finish verifying you.
Other privacy rights
-
you may object to the
processing of your personal
data
-
you may request correction
of your personal data if it
is incorrect or no longer
relevant, or ask to restrict
the processing of the
data
-
you can designate an
authorized agent to make a
request under the CCPA on
your behalf. We may deny a
request from an authorized
agent that does not submit
proof that they have been
validly authorized to act on
your behalf in accordance
with the CCPA.
-
you may request to opt-out
from future selling of your
personal information to
third parties. Upon
receiving a request to
opt-out, we will act upon
the request as soon as
feasibly possible, but no
later than 15 days from the
date of the request
submission.
To exercise these rights, you
can contact us contact@getcinder.com ,
12. DO WE MAKE
UPDATES TO THIS
NOTICE?
In Short:
Yes, we will update this
notice as necessary to stay
compliant with relevant
laws.
We may update this privacy
notice from time to time. The
updated version will be
indicated by an updated
"Revised" date and the updated
version will be effective as
soon as it is accessible. If
we make material changes to
this privacy notice, we may
notify you either by
prominently posting a notice
of such changes or by directly
sending you a notification. We
encourage you to review this
privacy notice frequently to
be informed of how we are
protecting your
information.
13. HOW CAN YOU
CONTACT US ABOUT THIS
NOTICE?
If you have questions or
comments about this notice,
you may
contact@getcinder.com ,
14. HOW CAN YOU
REVIEW, UPDATE, OR
DELETE THE DATA WE
COLLECT FROM
YOU?
Based on the applicable laws
of your country, you may have
the right to request access to
the personal information we
collect from you, change that
information, or delete it in
some circumstances. To request
to review, update, or delete
your personal information,
please
contact@getcinder.com