Privacy Policy

Last updated [February 18th, 2021]

This Privacy Policy forms part of and must be read in conjunction with, website Terms
and Conditions. We reserve the right to change this Privacy Policy at any time.

We respect the privacy of our users and every person who visits our sites Abc.com. Here,
ABC refers to as (“we”, “us”, or “our”). We are committed to protecting your personal
information and your right to privacy under the General Data Protection Regulation
(GDPR). If you have any questions or concerns about our policy or our practices with
regards to your personal informaticon, please contact us at [email protected].

When you visit our website Abc.com (“Site”) and use our services, you trust us with your
personal information. We take your privacy very seriously. In this privacy notice, we
describe our privacy policy. We seek to explain to you in the clearest way possible what
information we collect, how we use it and what rights you have concerning it. We hope
you take some time to read through it carefully, as it is important. If there are any terms
in this privacy policy that you do not agree with, please discontinue the use of our site
and our services.

This privacy policy applies to all information collected through our website, and/or any
related services, sales, marketing or events (we refer to them collectively in this privacy
policy as the “Site“).

Please read this privacy policy carefully as it will help you make informed decisions
about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us

We collect personal information that you voluntarily provide to us when expressing an

interest in obtaining information about us or our products when participating in
activities on the Site or otherwise contacting us.

The personal information that we collect depends on the context of your interactions
with us and the Site, the choices you make, and the products and features you use. The
personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal
address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information

used for authentication and account access.

Payment Data. We 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 by our payment processor and you should review its privacy policies and contact
the payment processor directly to respond to your questions.

Information automatically collected

We automatically collect certain information when you visit, use or navigate the Site.
This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address,
browser and device characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when you use our Site
and other technical information. If you access our site with your mobile device, we may
automatically collect device information (such as your mobile device ID, model and
manufacturer), operating system, version information and IP address. This information is
primarily needed to maintain the security and operation of our Site, and for our internal
analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar
technologies. You can find out more about this in our Cookie Policy.

Information collected from other Sources

We may obtain information about you from other sources, such as public databases,
joint marketing partners, social media platforms (such as Facebook), as well as from
other third parties.

If you have chosen to subscribe to our newsletter, your first name, last name and e-mail
address will be shared with our newsletter provider. This is to keep you updated with
information and offers for marketing purposes.

2. HOW DO WE USE YOUR INFORMATION?

We use your personal information for these purposes in reliance on our legitimate
business interests (“Business Purposes”), to enter into or perform a contract with you
(“Contractual”), with your consent (“Consent”), and/or for compliance with our legal
obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on
next to each purpose listed below.

We use the information we collect or receive:

 To send administrative information to you for related to your account, our

business purposes, and/or for legal reasons. We may use your personal
information to send you a product and new feature information and/or
information about changes to our terms, conditions, and policies.
 Deliver targeted advertising to you for our Business Purposes and/or with your
Consent. We may use your information to develop and display content and
advertising (and work with third parties who do so) tailored to your interests
and/or location and to measure its effectiveness. [For more information, see
our Cookie Policy.
 Request Feedback for our Business Purposes and/or with your Consent. We may
use your information to request feedback and to contact you about your use of
our Site.
 To protect our Site for Business Purposes and/or Legal Reasons. We may use
your information as part of our efforts to keep our Site safe and secure (for
example, for fraud monitoring and prevention).
 To enable user-to-user communications with your consent. We may use your
information to enable user-to-user communications with each user’s consent.
 To enforce our terms, conditions and policies for our business purposes and
as legally required.
 To respond to legal requests and prevent harm as legally required. If we
receive a subpoena or other legal request, we may need to inspect the data we
hold to determine how to respond.
 For other Business Purposes. We may use your information for other Business
Purposes, such as data analysis, identifying usage trends, determining the
effectiveness of our promotional campaigns and to evaluate and improve our
Site, products, services, marketing and your experience.

3. WILL YOUR INFORMATION BE SHARED

WITH ANYONE?
We only share and disclose your information in the following situations:
 Compliance with Laws. We may disclose your information where we are legally
required to do so to comply with applicable law, governmental requests, a
judicial proceeding, court order, or legal processes, 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 and Legal Rights. 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.
 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.
 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.
 Third-Party Advertisers. We may use third-party advertising companies to serve
ads when you visit the Site. These companies may use information about your
visits to our Site and other websites that are contained in web cookies and other
tracking technologies to provide advertisements about goods and services of
interest to you.
 Affiliates. We may share your information with our affiliates, in which case we
will require those affiliates to honor this privacy policy. Affiliates include our
parent company and any subsidiaries, joint venture partners or other companies
that we control or that are under common control with us.
 Business Partners. We may share your information with our business partners to
offer you certain products, services or promotions.
 With your Consent. We may disclose your personal information for any other
purpose with your consent.
 Other Users. When you share personal information (for example, by posting
comments, contributions or other content to the Site) or otherwise interact with
public areas of the Site, such personal information may be viewed by all users
and may be publicly distributed outside the Site in perpetuity.

4. DO WE USE COOKIES AND OTHER

TRACKING TECHNOLOGIES?
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 Policy.

5. IS YOUR INFORMATION TRANSFERRED

INTERNATIONALLY?
We will not transfer your personal information to an overseas recipient.

6. Analytics and advertising

Google Analytics

This website uses Google Analytics, a web analytics service. It is operated by Google Inc.,
1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called "cookies". These are text files that are stored on your
computer and that allow an analysis of the use of the website by you. The information
generated by the cookie about your access and use of this website is usually transmitted
to a Google server in the USA and stored there.

Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator
has a legitimate interest in analyzing user behavior to optimize both its website and its
advertising.

7. WHAT IS OUR STANCE ON THIRD-PARTY

WEBSITES?
The Site may contain advertisements from third parties that are not affiliated with us
and which may link to other websites, online services or mobile applications. We cannot
guarantee the safety and privacy of data you provide to any third parties. Any data
collected by third parties is not covered by this privacy policy. We are not responsible
for the content or privacy and security practices and policies of any third parties,
including other websites, services or applications that may be linked to or from the Site.
You should review the policies of such third parties and contact them directly to
respond to your questions.
 8. HOW LONG DO WE KEEP YOUR
INFORMATION?
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy policy unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements).

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize it, 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.

9. HOW DO WE KEEP YOUR INFORMATION

SAFE?
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However,
please also remember that we cannot guarantee that the internet itself is 100% secure.
Although we will do our best to protect your personal information, the transmission of
personal information to and from our Site is at your own risk. You should only access
the services within a secure environment.

10. DO WE COLLECT INFORMATION FROM

MINORS?
We do not knowingly solicit data from or market to children under 16 years of age. By
using the Site, you represent that you are at least 16 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Site. If we
learn that personal information from users less than 16 years of age has been collected,
we will deactivate the account and take reasonable measures to promptly delete such
data from our records. If you become aware of any data we have collected from
children under age 16, please contact us at [email protected]

11. WHAT ARE YOUR PRIVACY RIGHTS?

.Personal Information

You may at any time review or change the information in your account or terminate
your account by:

 Contacting us using the contact information provided below

Upon your request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, some information may be retained
in our files to prevent fraud, troubleshoot problems, assist with any investigations,
enforce our Terms of Use and/or comply with legal requirements.

Opt-Out (RIGHT TO RESTRICT PROCESSING)

General

You have the right to opt-out of certain uses and disclosures of your Personal
Information. Where you have consented us for Processing of your Personal Information,
you may withdraw that consent at any time and opt-out to further Processing by
contacting [email protected]. Even if you opt-out, we may still collect and use non-Personal
Information regarding your activities on our Services and/or information from the
advertisements on Third-Party websites for non-interest-based advertising purposes,
such as to determine the effectiveness of the advertisements.

Telephone Communications

We may also send you certain non-promotional communications regarding our Services
and you will not be able to opt-out of those communications (e.g., communications
regarding updates to our Terms or this Privacy Policy).

Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or
remove them from your browser by adjusting your web browser preferences. Please
note that cookie-based opt-outs are not effective on website. However, on many
devices, App users may opt-out of certain ads via their device settings.

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 will still need to send you service-related emails that are necessary for
the administration. You can also opt-out by:

 Contacting us using the contact information provided below.

“Do Not Track” Signals: Some third party browsers provide “do not track” machine
readable signals for websites which are automatically applied by default and therefore
do not necessarily reflect our visitor’s choice as to whether they wish to receive
advertisements tailored to their interests. As a result, at this time, we do not respond to
browser “do not track” signals or other similar mechanisms.
Visit http://www.networkadvertising.org or http://www.aboutads.info if you wish to learn
more about your options to not accept tracking cookies for the purpose of receiving
targeted interest-based advertisements. Please note that the-opt out is cookie-based
and will only affect the specific computer and browser on which the opt-out is applied.

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 Site.

12. DATA PROTECTION OFFICER

We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing
questions about this privacy notice. If you have any questions about this privacy notice,
including any requests to exercise your legal rights, please contact Data Protection
Officer, at our e-mail [email protected]

13. COPPA – Children’s Online Privacy Policy

Website www.abc.com is focused on ensuring the security of children’s visiting this site.
This Children’s Online Privacy Policy clarifies our information gathering, disclosure, and
parental consent practices concerning personal information provided by children under
the age of 13 (“child” or “children”), and uses terms that are defined in our Privacy
Policy.

Collection of Information, Use of it and Communication with Parents

Children can inspect the site and can assess and print content without giving any
individual data other than the automatic collection of device ”persistent identifiers,”
examined in more detail beneath. This site just gathers limited individual data. In the
event, the data gathered does not permit contact with him or her or his or her gadget
(counting, for instance, collected data), we may utilize and uncover it for any reason, to
the degree allowed by applicable law.

Personally Identifiable Information

In keeping with the Children’s Online Privacy Protection Act of 1998, we do not
knowingly collect personally identifiable information from children under the age of 13
without prior verifiable parental consent. If we learn that we have collected such
personal information without parental consent, we will delete that information from our
records.

Persistent Identifiers

At the point when children collaborate with the site, certain technical data may
consequently be gathered, both to make our site more interesting and helpful and for
different internal purposes identified with our business. Examples of data that is
automatically gathered include the type of computer operating system, the device’s IP
address or mobile device identifier, the web browser, the frequency with which the child
visits various parts of our site, and information regarding the online or mobile service
provider. This data is gathered utilizing techniques, for example, flash cookies, web
beacons, and other unique identifiers (which we define under the ”Cookies and Other
Technologies” section of our general Privacy Policy). This data might be gathered by us
or by a third party. Persistent identifier information is used by abc.com for the sole
purpose of providing support for our internal operations, including to:

Ensure that the site functions properly; Enable us to conduct research and analysis to
understand, address, and improve the use and performance of the site; and Diagnose
and respond to problems.

How Parents may Raise Questions and Concerns?

If a parent has any questions or concerns about his or her child’s use of the site, we
encourage the parent to contact us at [email protected].

14. CALIFORNIA PRIVACY RIGHTS

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.

ACCESS AND DATA PORTABILITY RIGHTS

You have the right to request that we disclose certain information to you about our
collection and use of your Personal Information over the past 12 months. Once we
receive and confirm your verifiable consumer request, we will disclose to you:

 The categories of Personal Information we collected about you.

 The categories of sources for the Personal Information we collected about you.
 Our business or commercial purpose for collecting or selling that Personal
Information.
 The categories of third parties with whom we share that Personal Information.
 The specific pieces of Personal Information we collected about you (also called a
data portability request).
 If we sold or disclosed your Personal Information for a business purpose, two
separate lists disclosing (i) sales, identifying the Personal Information categories
that each category of recipient purchased; and (ii) disclosures for a business
purpose, identifying the Personal Information categories that each category of
recipient obtained.

DELETION REQUEST RIGHTS

You have the right to request that website to delete your Personal Information, subject
to certain exceptions. Once we receive and confirm your verifiable consumer request, we
will delete (and direct our service providers to delete) your Personal Information from
our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or
our service provider(s) to:

 Complete the transaction for which we collected the Personal Information,

provide a good or service that you requested, take actions reasonably anticipated
within the context of our ongoing business relationship with you, or otherwise
perform our contract with you.
 Detect security incidents, protect against malicious, deceptive, fraudulent, or
illegal activity (including fraudulent user-generated content such as product
reviews), or prosecute those responsible for such activities.
  Debug products to identify and repair errors that impair existing intended
functionality.
 Exercise a right provided for by law.
 Comply with the California Electronic Communications Privacy Act (Cal. Penal
Code § 1546 et. seq.).
 Engage in public or peer-reviewed scientific, historical, or statistical research in
the public interest that adheres to all other applicable ethics and privacy laws,
when the information’s deletion may likely render impossible or seriously impair
the research’s achievement if you previously provided informed consent.
 Enable solely internal uses that are reasonably aligned with consumer
expectations based on your relationship with us.
 Comply with a legal obligation.
 Make other internal and lawful uses of that information that are compatible with
the context in which you provided it.

EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described above, please
submit a verifiable consumer request to us by sending us a message on our website. Only
you, or a person registered with the California Secretary of State that you authorize to
act on your behalf, may make a verifiable consumer request related to your Personal
Information. You may also make a verifiable consumer request on behalf of your minor
child.
You may only make a verifiable consumer request for access or data portability twice
within 12 months. The verifiable consumer request must:

 Provide sufficient information that allows us to reasonably verify you are the
person about whom we collected Personal Information or an authorized
representative.
 Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we

cannot verify your identity or authority to make the request and confirm the Personal
Information relates to you.
We will only use Personal Information provided in a verifiable consumer request to
verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time, we will inform you of the reason and extension period
in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12 months preceding the verifiable
consumer request’s receipt. The response we provide will also explain the reasons we
cannot comply with a request, if applicable. For data portability requests, we will select a
format to provide your Personal Information that is readily useable and should allow
you to transmit the information from one entity to another entity without hindrance,
specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will tell you why we made that decision and provide you with
a cost estimate before completing your request.

OPT-OUT AND OPT-IN RIGHTS

If you are 16 years of age or older, you have the right to direct us to not sell your
Personal Information at any time (the “right to opt-out”). We do not sell the Personal
Information of consumers if less than 16 years of age unless we receive affirmative
authorization (the “right to opt-in”) from either the consumer who is between 13 and 16
years of age or the parent or guardian of a consumer less than 13 years of age.
Consumers who opt-in to Personal Information sales may opt-out of future sales at any
time.
exercise the right to opt-out, you (or your authorized representative) may submit a
request to us at email: [email protected].
We will only use Personal Information provided in an opt-out request to review and
comply with the request.

NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. However,
note that many features of our website, our products, or our services will not function
without your Personal Information. Unless permitted by the CCPA, we will not:

 Deny you goods or services.

 Charge you different prices or rates for goods or services, including through
granting discounts or other benefits, or imposing penalties.
 Provide you a different level or quality of goods or services.
 Suggest that you may receive a different price or rate for goods or services or a
different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can
result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive
we offer will reasonably relate to your Personal Information’s value and contain written
terms that describe the program’s material aspects. Participation in a financial incentive
program requires your prior opt-in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users who are
California residents to request certain information regarding our disclosure of Personal
Information to third parties for their direct marketing purposes. To make such a request,
please send us an electronic message through our website or write us at our email
address listed on our webpage.

15. DO WE MAKE UPDATES TO THIS

POLICY?
We may update this privacy policy 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 policy, 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 policy frequently to be informed
of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT

THIS POLICY?
If you have questions or comments about this policy, email us at [email protected].