We at Grasby (“Grasby” “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our website and use our services (“Site” and “Services”, respectively). This Privacy Notice also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. “You” means any adult user of the Site and/or Services, or any parent or guardian of any minor whom you allow to use the Site and/or Services, and for whom you will be held strictly responsible.
Sophomore is the data controller in respect of the processing activities outlined in this Privacy Notice.
“Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
Information We Collect
We collect information from you when you choose to use our Site and/or Services. In order to register a product and/or receive related Services and/or make a purchase through the Site, you will be required to provide us with certain Personal Information. We also collect Personal Information when you make use of the Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.
Examples of the Personal Information that we collect from you may include your name, email address, phone number, postal address, and credit card details. Such Personal Information may be collected by us through the Site.
In addition, when you use the Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and purchase history on our Site. It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register your product and/or provide you with the Services.
How We Use Your Personal Information
We and any of our trusted third-party subcontractors and service providers may use the Personal Information we collect from and about you for any of the following purposes: (1) to provide you with the Site and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail; (5) to contact you with informational newsletters and promotional materials relating to our Site and Services and with miscellaneous updates regarding our product; (6) to review the usage and operations of our Site and Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services and (9) to provide customer support.
By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners without restriction, on commercial terms that we can determine in our sole discretion.
We may use your Personal Information as required or permitted by any applicable law.
Basis for Processing Your Personal Data
Processing your Personal Information is necessary for the provision of the Site and Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support.
Processing your Personal Information for third-party marketing purposes is based upon your consent. When visiting the Site, you shall be asked to accept the terms of this Privacy Notice, including the processing of your Personal Information for marketing purposes. You may withdraw your consent to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes at any time by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
Processing for the purposes of developing and enhancing our products and services, for analytics and usage analysis, for the marketing of our products and services, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
Disclosure of Information
We may share your information, including Personal Information, as follows:
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Information we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Site and/or Services; (2) aid in their understanding of how users are using our Site and Services; (3) provide to you targeted offers and advertising on our Site and on other sites you choose to visit, subject to your consent as may be required under applicable law.
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Information). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
We may transfer our databases containing your Personal Information if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Information, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation, subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at email@example.com.
Other Uses or Transfer of Your Information
We allow you to use our Site and Services in connection with third-party services, sites, and/or mobile applications. If you use our Site and/or Services with or through such third-parties, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.
How We Protect Information
We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
If you have not disabled third party cookies (please see section on Cookies below), and you use our Site or Services, additional third parties may also be serving as controllers in connection with the collection of your Personal Data. You can read more about third party cookies below.
How to Access and Limit Our Use of Certain Information
You have certain rights in relation to the Personal Information that we or our co-controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly at the information provided. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories (the type of cookie and why we use it):
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
For your convenience, below are links to instructions on how to change your cookie settings in several popular internet browsers:
By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device.
Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.
Third Party Cookies
Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.
Displaying Content From External Platforms
These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them. If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.
Interaction With External Social Networks And Platforms
These services allow interaction with social networks or other external platforms directly from the pages of this Application.
Twitter Tweet Button and Social Widgets (Twitter)
Facebook Like Button and Social Widgets (Facebook)
Managing Email Addresses And Sending Communications
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at SUPPORT EMAIL. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them.
We may use third party services that make it possible to manage a database of subscription based email contacts to communicate with the User via email. The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the User interacts with incoming mail, such as by clicking on the links included in the email.
We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
When visiting this Site, you shall be asked to accept the terms of this Privacy Notice. If you do not agree with the terms hereof, please do not use the Site. We may update this Privacy Notice from time to time in which case, we shall notify you of such changes. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
Comments and Questions
Data Controller And Owner
Copyright © 2022 Grasby. All rights reserved.
Updated by Grasby, on July 29 2022.