Always Sparkly Websites, its subsidiaries and other entities within its corporate group structure (collectively, “we”, “us”, “our” or “ASW”) respect the privacy of our users and we are committed to informing you about how we collect, use, and share Personal Information about you which is submitted by you or on your behalf.
Personal Information and Other Information Processed by Us
(i) “Personal Information” is information relating to a person who is identified in that data or who is, together with other data, identifiable; and
(ii) “Other Information” is any additional information that ASW collects about our users that is not Personal Information.
We may use your contact information to send you information about the Services. You may unsubscribe from some of these messages by using the unsubscribe link provided in each email, although, we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.
Personal Information we collect: we may combine Personal Information collected through ASW Website with Other Information that we or third parties collect about you in other contexts—such as our communications with you via email, phone or otherwise or your customer service records and travel details. Additionally, if you register for or access ASW Website using a third party service, we may receive Personal Information that you allow such third party service to share with us. You acknowledge that this information may be personal to you, and by creating an account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous.
Other Information we collect: each time you log onto your account or use AWS Website, we may, in some cases automatically, collect the following information:
• through your device: we may collect information from or through the device you use to connect to AWS Website, including, for example, the type of device, the IP address, the approximate location derived from an IP address, the mobile network,
the operating system and version, the browser and version or the timezone setting or unique device identifiers.
• log information: we automatically receive and record certain details about your use of AWS Website, including but not limited to, web traffic data, weblogs and communication data, information about your activity on AWS Website.
• other information from other sources: we work with third parties (including, for example, providers in technical, payment services, advertising networks, analytics providers and search information providers), and we may receive, collect, store, and use information about you from them. We may partner with certain third parties to collect the Other Information and to engage in analysis, auditing, research, and reporting or for use in providing online interest-based advertising on our behalf. These third parties may use weblogs or web beacons, and they may set and access cookies or similar technologies on your device. They may also use information about your use of AWS Website to help target non-AWS advertisements based on your online activity in general.
• information from email communications: we may communicate with you via email, SMS, MMS or other text message (collectively, “Text Message”) or push notifications (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email. We use this information to improve the Services, including without limitation our customer service.
• information related to advertising and use of beacons: to support and enhance the Services, we may serve advertisements, and also allow third parties advertisements, through AWS Website. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. Advertisements served through AWS Website may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age); (ii) AWS Website usage patterns or (iii) user activity on third-party services. We do not provide Personal Information to any ad networks for use outside of AWS Website. To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through AWS Website. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site. You can opt out of certain types of targeted advertising as further described in the section below titled ‘Your Rights.’
• aggregate information: we collect statistical information about how both unregistered and registered users, collectively, use the AWS Website (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your account or your web browser.
How We Use Your Personal Information
AWS may use the information that we collect from you:
• to provide services to you: we use Personal Information to provide our services to you through AWS Website, to process and complete payments or transactions and to provide customer support. We may use the information we collect from you in the following ways: to personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested; to improve our website in order to better serve you; to allow us to better service you in responding to your customer service requests; to administer a contest, promotion, survey or other site feature; to quickly process your transactions; to send periodic emails regarding your order or other products and services; to follow up with them after correspondence (live chat, email or phone inquiries). We also may use Personal Information to improve the Services.
• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications. Such communications are designed to make your AWS more efficient and may include, but are not limited to: notifications about the Services (including important news that could affect your relationship with us), communications about our services and promotion. These types of communications may also contain commercial messages, such as banner ads and special offers. By using the Services, you consent to the receipt of such communications and marketing information.
• for legal purposes: we may use and share Personal Information for legal purposes, including as described below in the section titled ‘How We Share Information with Third Parties’ (including the transfer of such Personal Information to third parties in countries outside of your country of residence where data protection laws may be less adequate compared to your own country’s data protection laws).
• for our business purposes: we may use Other Information to help us efficiently operate AWS and it’s Website, to count and recognize visitors to AWS Website, to enable certain features on AWS Website and for other purposes related to managing our business.
• for other purposes: subject to applicable law, we may use Other Information for additional purposes in connection with AWS Website, including any purpose for which we may use Personal Information, as described above.
AWS may link Other Information with Personal Information. In those circumstances, we will treat the combined information as Personal Information.
How We Share Information with Third Parties
Subject to applicable law, we may share your Personal Information and Other Information:
• with partners and other third-party service providers: to operate AWS Services, including processing your transactions and supporting your activities on a AWS tri, we may share your Personal Information with our partners and other service providers. These service providers may provide us with support services such as origination of communications, receipt or support services, customer relationship management services and order fulfillment.
• with third-parties through their websites: AWS Website may enable you to share information directly on or through websites or online services operated by third parties. For example, AWS Website may contain links to third-party websites. If you choose to browse such websites, you may disclose your Personal Information to those third-party websites. AWS is not liable for the content or action of such third-party websites.
• user information: some of your activity and information provided on and through AWS Website may be public (such as your name, logo, and testemonial). Please remember that if you choose to provide Personal Information using certain public features of AWS Website, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We, therefore, urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through AWS Website. Additionally, profile information including your name and other information you enter may be displayed to other clients to facilitate client interaction within AWS Website. We will not directly reveal user email addresses to other clients.
• with our agents: we also employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.
• pursuant to business transfers: in some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
• aggregated information: from time to time, AWS may also share anonymized and aggregated information about users of the Services such as by publishing a report or providing information to our business partners on trends in the usage of the Services and demographics of users. We use and share this type of data so that we and our business partners can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these business partners may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.
• financial information: as stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through AWS Website, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.
• information we share with your consent: except as set forth above, you will be notified when your Personal Information may be shared with third parties and will be able to prevent the sharing of this information.
We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an account. We may also supplement the information we collect from you with information received from third parties in order to enhance our services or to offer you information that may be of interest to you.
Most browsers automatically accept cookies and have an option for turning off the cookie feature, which will prevent the browser from accepting new cookies, as well as (depending on the sophistication of the browser software) allowing the user to decide on the acceptance of each new cookie in a variety of ways. If you choose to decline cookies, some parts of AWS Website may not work as intended or may not work at all. For more details, see aboutcookies.org.
Please reference the chart below to learn more about the kinds of cookies we use and for what purpose.
• Essential Cookies
Essential cookies are cookies that enable you to navigate and use all the features provided through our Services. Without these, you would not be able to navigate between pages and be served various pages.
Examples: encrypted and cryptographically signed session cookie, used to identify you to our servers after you log in; flash: temporarily stores messages and alerts that we display on – screen to you.
• Functionality Cookies
These cookies enable us to remember you have visited us before, including any preferences you have provided and/or selected to give you a tailored experience.
Tags: _rails_app_session, rack.session, ryu_brid
• Performance and Analytical Cookies
This information is used to help us understand your interactions with the Services. We use this information with various analytics applications to improve the Services and better target various offerings to users.
Examples: ga : Google Analytics identifier.
We use third parties, for example, Google Analytics, to analyze statistical information from users of our Services.
Tags: Google Analytics (Analytics), Google Optimize, Facebook Pixel (Conversions), Bing UET Conversion Pixel
• Retargeting or Advertising Cookies
Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on AWS Website and on other websites and online services. Targeting and advertising cookies we use may include Google Analytics, Facebook Pixel, LinkedIn Insights tag and others.
Where We Store Your Information
The information that we collect from you may be transferred to, and stored at, a destination (a “third country”) outside the country or region in which you are resident or use AWS Website, including in the United States of America where data protection laws are not deemed to be as adequate as other regions (e.g. Europe). The data protection laws in these third country countries may be less adequate compared to your country of residence. By using AWS Website, you agree to this transfer, storing or processing of your laws in such third countries.
Our Security Precautions
AWS uses commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification or deletion but no security program can be guaranteed to be 100% secure. As a result, AWS cannot guarantee the security of any information obtained or processed by AWS or its service providers, and you use AWS Website at your own risk.
You may, under applicable law, have the right to ask us not to process your Personal Information for marketing purposes. If you do not wish to receive marketing communications from AWS, please follow the opt-out instructions contained in each such communication or any time by contacting us at [email protected] Please note that you may not be able to opt-out of certain non-marketing communications about your account or communications that are reasonably necessary to provide services to you, and that opting-out of receiving text messages or other communications, as applicable, may impact your use of AWS Website or may limit AWS’s ability to provide services to you.
Please note that it may take up to 30 days for your withdrawal to be reflected in our systems following confirmation of your request to opt-out. Therefore, you may still receive certain communications during this period.
Opting out of Interest-Based Advertising
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative opt-out page or permanently using the Google Analytics Opt-Out Browser Add-on.
Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties and to opt out of receiving certain cookies and certain trackers, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices or http://youronlinechoices.eu.
Do Not Track
Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. AWS Website does not currently support the Do Not Track options offered by most major browsers. For more information about DNT signals, visit http://allaboutdnt.com.
Accessing & Editing Your Information
AWS provides you with the ability to view, update, access, edit and correct your Personal Information by contacting our team at [email protected] Personal Information transmitted through boards, chats, polls or any other means may remain in our databases, except to the extent prohibited under applicable law.
You may have additional rights under applicable law to access the information we hold or share about you but any access request may be subject to a reasonable fee, to the extent permissible under applicable law, to meet our costs in providing you with details of such information.
We reserve the right to verify your information and can exercise our absolute discretion not to provide any Services to you if we are not satisfied that you are an adult. If a child has provided us with Personal Information, a parent or legal guardian of that child may contact us as described below. Upon confirmation, we will then make reasonable efforts to delete the child’s Personal Information from our applicable database.
NOTICE FOR RESIDENTS OF THE EU, UK, LICHTENSTEIN, NORWAY, OR ICELAND
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure [email protected] will be the controller of your Personal Data processed in connection with the Services.
What Personal Data Do We Collect From You? We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
• Contact and identification information (e.g. name, email address, social media accounts)
• Residency information (e.g. country of citizenship and city or postal code, country of primary bank account)
• Personal details (e.g. employer, remote work experience, work schedule, work goal)
Information we receive from third-party sources: Some third parties such as your employer, our Payment Processors, or our advertising partners provide us with Personal Data about you, such as the following:
• Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third-party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.
• Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.
• Information from your employer: If we have a partnership with your employer we may receive information about you from them.
Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:
• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Location information (e.g. IP address, zip code)
• Log data (e.g. access times, hardware and software information)
How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
• Provide AWS Website and meet our contractual obligations
• Create and manage user profiles
• Communicate with you about the Services
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Services
• Personalize website content and communications based on your preferences
• Respond to user inquiries
• Fulfill user requests
• Analyze demographics for business insights
• Comply with our legal or contractual obligations
• Analyze demographics for business insights
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms and Conditions
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms and Conditions, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
o Contact and identification information (e.g. name, email address)
o Business information (e.g. business name, business address)
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
o Contact and identification information (e.g. social media accounts)
o Personal details (e.g. remote work experience, work schedule, work goals)
o Contact and identification information (e.g. social media accounts)
Examples of these legitimate interests include:
o Operation and improvement of our business, products and services
o Marketing of our products and services
o Provision of customer support
o Protection from fraud or security threats
o Compliance with legal obligations
o Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
• Payment processors
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Hosting service providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
• Social media services (if you interact with them through your use of the Services)
• Third-party business partners who you access through the Services
• Other parties authorized by you We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:
• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example, to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.
Personal Data of Children: As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from someone under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us with Personal Data, please contact us at [email protected].
What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data: The Services are hosted and operated in the Republic of Serbia (“R.S.”) through Company and its service providers, and if you do not reside in the R.S., laws in the R.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the R.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the R.S., and possibly other countries.