Last Revised: September 19, 2018
Who is responsible for the processing of your data?
Address: Calle Aquilino de la Guardia No.8, Panama City, Panama.
Contact Data Protection Office: [email protected]
How will we process your data?
1. Information Collection
You generally are not required to provide information about yourself when you visit the Services. However, we may ask you for some or all of the following types of information when you register with our Services, sign up for contests or sweepstakes, participate in surveys, access various content or features, submit comments or content, use a send-to-a-friend feature, or directly contact us with questions or feedback:
Contact information, such as name, e-mail address and telephone number;
Unique identifiers, such as a user name or password;
Demographic information, such as gender;
Real-time Geolocation information;
Comments and other information posted in our interactive online forums;
Correspondence and other information that you send to us; and
Additional information as otherwise described to you at the point of collection or pursuant to your consent.
If you decide not to provide this information, it may limit our ability to provide some of the above content.
We also may collect certain information automatically when you visit the Services, including:
Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
Your device type or mobile carrier;
Other unique identifiers, including mobile device identification numbers; and advertising identifiers (e.g., IDFA);
Your browser type and operating system;
Sites you visited before and after visiting the Services;
Pages you view and links you click on within the Services;
Information collected through cookies, web beacons, Local Shared Objects, and other technologies;
Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded; and
Standard Server Log Information
2. Use of Information
We may use information that we collect through the Services for a variety of purposes, including to:
Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
Contact you via email and otherwise about your account;
Conduct analysis on fan behaviour in order to better serve you with offers and content that is of interest to you;
Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
Publish stories, comments, photos, and other information posted in our interactive online features;
Customize and personalize your use of the Services, including providing you with tailored advertising; and
As otherwise described to you at the point of collection or pursuant to your consent.
3. Sharing of Information
Limited members of Eclectica Marketing Team and IT departments, as well as the third party vendor that processes fan data on behalf of Eclectica may access and otherwise process personal information in connection with their job responsibilities or contractual obligations.
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. At times, as described below, we may share your personal information with others for the purposes described above:
Service Providers: We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, provide customer service, or send communications for us). We may share information with third-parties, such as social networking platforms, so that they may send tailored communications on our behalf via their platforms. These companies are authorized to use your personal information only as necessary to provide these services to us.
Select Business Partners: With your prior permission, we may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, you may be presented with an opportunity to have certain information shared with our third party business partners when you enter a contest or sweepstakes or elect to receive marketing offers or other information. If you do not elect to have your information shared, it will not be shared with such third parties. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.
Third-Party Ad Serving and Audience and Traffic Measurement Services: We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users’ online activities over time and across different websites.
Interactive Features: We may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.
Other Parties With Your Consent: We may share information with third parties when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.
Aggregate Information: We may share aggregate information, such as demographics and usage statistics, with advertisers, sponsors or other organizations.
Geolocation Information: We may share your geolocation information with service providers that perform certain functions or services on our behalf. These companies are authorized to use precise geolocation information only as necessary to provide these services to us. We also may share your geolocation information with third parties so that they may provide you with geographically relevant advertising. If you wish to stop the further collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology, please opt-out using your device settings.
4. Cookies and Similar Technologies
We may use mobile analytics software to allow us to better understand the functionality of our Services. This software may record information such as how often you use an application, the events that occur within the application, aggregated usage, performance data, and where an application was downloaded from.
6. Social Networking
7. Links to Other Websites
8. Data Security and Data Integrity
We have adopted security procedures to help protect against loss, misuse, interference, disclosure, destruction, alteration and unauthorized access to the information you provide to us. We encrypt the transmission of that information using secure socket layer technology (SSL). We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.
Please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
9. Data Retention
We will retain your information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our website and receipt of our Services.
10. Children’s Privacy
The Services do not knowingly collect, use, or disclose personal information from children under the age of 13. If we are made aware we have collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act (“COPPA”), we will delete this information as soon as possible.
11. Communications Preferences and Access
You may choose to receive promotional emails, newsletters, push notifications, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. You may opt out of receiving push notifications by turning off push notifications at the device level. Please note that opt-out requests may take some time to be effective.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
13. International Users
Please note that the Services are directed towards users who reside in Latin America. Our website is hosted in Panama. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to Panama, pursuant to the laws of Panama. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Policy and take appropriate steps to ensure that recipients of your information are bound to duties of confidentiality and where applicable we implement measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure.
14. Users from the European Union
In compliance with the provisions of current legislation on data protection, and in the context of the new regulatory framework established by virtue of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of said data (hereinafter, the “General Regulations”), and the national regulations on the protection of personal data, we inform you that the personal data that you provide us (hereinafter, the “Data”), will be subject to processing by Eclectica.
Eclectica is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”) when you use the Services.
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our Services, and for you to use all the features of our website.
Automated Decision-Making: We use automated decision-making technologies, including profiling, to support our data processing activities. Our automated decision-making capabilities include logic that will send triggered messages based on fan data or behaviour. By using this logic, it helps us provide a better fan experience or you, this means that receiving messages based on data you have provided (for example a birthday email) or a behaviour (watching a video).
Your Rights: You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, of (e.g. if your Personal Data changes or is out of date), erasure of and portability of your own Personal Data in certain circumstances. Requests should be submitted by contacting us by emailing [email protected]
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with your local supervisory authority if you consider that our processing of your Personal Data infringes applicable law.