We ask that you read this privacy notice carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Traction Management s.r.l. (“Traction,” “We,” or “Us”) collects, uses and is responsible for certain personal information about you, as part of the emailurgency website (located at emailurgency.com) and the online email countdown timer application (collectively, the “Service”).
For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.
personal information when you provide it to us:
statistics (your “Analytic Information”)
Information shared with us by others: If you make a payment through our payment processor, Stripe, they may share information about your subscription level with us.
How we use your Personal Information: We use your personal information as follows:
Who we share your Personal Information with: We share your Personal Information with certain third parties as part of our operation of the Service. This data sharing enables you to make purchases on the Service and for us to provide you with the Service in the optimal way.
Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.
We share your Personal Information with the following third parties:
Analytics: We use third party website and application analytic tools such as Google Analytics and Mixpanel on the Service, that employ cookies to collect certain Analytic Information concerning your use of the Service. You can find their privacy policies at the links below:
We will share your Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Service, or (iii) such action is appropriate to protect the rights, property or safety of Traction, its employees, clients, or users of the Service.
We will not share your personal information with any other third party.
How long your Personal Information will be kept: We will keep your Personal Information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide.
Please note that some data may be retained if necessary to resolve disputes, enforce Traction user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Service.
Reasons we can collect and use your Personal Information: The laws in some jurisdictions require that we notify you of the lawful basis for collecting your Personal Information.
To the extent that such laws apply, we rely on the following as the lawful basis on which we collect and use your personal information:
Additionally, we may at times have to transfer or receive your personal data to or from third parties, in order to fulfill other contractual obligations to you. For example, we may have to transfer or receive billing and payment information to or from payment processors for any purchases you make.
Cookies: When you use the Service, cookies may be used by us and by third parties to allow the Service to function, to allow you to stay logged in between different sessions, and to help to make your user experience better.
Cookies are not spyware or adware, and can’t deliver viruses or run programs on your computer. You may configure your web browsers to accept, reject, or delete cookies, or to notify you when a cookie is being set. We may also use “pixel tags,” otherwise known as web beacons or clear gifs. These are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users.
Depersonalized Information: We may make your Personal Information non-personally identifiable by either combining or aggregating it with information about other users, or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information and is used to analyze usage and improve the Service.
Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, allow them to create accounts, sign up for newsletters, make purchases, or browse the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16.
Traction takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when on-line. If you have any concerns about your child’s personal information, please contact us at email@example.com
Do Not Track: Because there’s not yet a consensus on how companies should respond to web browser- based or other do-not-track mechanisms yet, we don’t respond to web browser-based do-not-track signals at this time.
Traction is based in the European Union. No matter where you are located, you consent to the processing, transfer and storage of your information in and to the European Union, and other countries, in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the European Union and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.
If you would like further information, please contact us to firstname.lastname@example.org
Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please email us at email@example.com. We may ask for additional verification information, such as your username and other information required to be sure that you are the owner of that data.
We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.
For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner. We also employ SSL encryption and Bcrypt password hashing to keep your personal information safe. Our web servers are located in a secured and environmentally controlled location, as well.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We hope that we can resolve any questions or concern you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.
If you are an EU citizen, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
This privacy notice was last updated on June 1, 2018.
We may change this privacy notice from time to time. When we do, we will inform you via email to the email address you have provided us with through your account, or by posting a message about the change on the Service.
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to firstname.lastname@example.org.