Effective date: 05/11/2020
1. Introduction
Welcome
to Retrica, Inc.
Retrica,
Inc. (“us”, “we”, or “our”) operates https://retrica.co and Retrica mobile application (hereinafter referred to as
“Service”).
Our Privacy Policy governs your visit
to https://retrica.co and Retrica mobile
application, and explains how we collect, safeguard and disclose information
that results from your use of our Service.
We use your data to provide and improve Service. By
using Service, you agree to the collection and use of information in accordance
with this policy. Unless otherwise defined in this Privacy Policy, the terms
used in this Privacy Policy have the same meanings as in our Terms and
Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy
Policy constitutes your agreement with us (“agreement”).
2. Definitions
SERVICE means
the https://retrica.co website and Retrica
mobile application operated by Retrica,
Inc..
PERSONAL DATA means
data about a living individual who can be identified from those data (or from
those and other information either in our possession or likely to come into our
possession).
USAGE DATA is
data collected automatically either generated by the use of Service or from
Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small
files stored on your device (computer or mobile device).
DATA CONTROLLER means
a natural or legal person who (either alone or jointly or in common with other
persons) determines the purposes for which and the manner in which any personal
data are, or are to be, processed. For the purpose of this Privacy Policy, we
are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any
natural or legal person who processes the data on behalf of the Data
Controller. We may use the services of various Service Providers in order to
process your data more effectively.
DATA SUBJECT is any living individual who is the subject of
Personal Data.
THE USER is the individual using our Service. The User
corresponds to the Data Subject, who is the subject of Personal Data.
3. Information Collection and Use
We collect several different types of information for
various purposes to provide and improve our Service to you.
4. Types of Data Collected
Personal Data
While
using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you (“Personal Data”). Personally
identifiable information may include, but is not limited to:
(a) Email
address
(b) First
name and last name
(c) Cookies
and Usage Data
(d) Sex
(e) Birthdate
or age
We may use your Personal Data to contact you with newsletters, marketing
or promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from
us by following the unsubscribe link.
Usage Data
We may also collect information that your browser
sends whenever you visit our Service or when you access Service by or through a
mobile device (“Usage Data”).
This Usage Data may include information such as your
computer's Internet Protocol address (e.g. IP address), browser type, browser
version, the pages of our Service that you visit, the time and date of your
visit, the time spent on those pages, unique device identifiers and other diagnostic
data.
When you access Service with a mobile device, this
Usage Data may include information such as the type of mobile device you use,
your mobile device unique ID, the IP address of your mobile device, your mobile
operating system, the type of mobile Internet browser you use, unique device
identifiers and other diagnostic data.
Location Data
We
may use and store information about your location if you give us permission to
do so (“Location Data”). We use this
data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you
use our Service at any time by way of your device settings.
Tracking Cookies Data
We use cookies and similar tracking technologies to
track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which
may include an anonymous unique identifier. Cookies are sent to your browser
from a website and stored on your device. Other tracking technologies are also
used such as beacons, tags and scripts to collect and track information and to
improve and analyze our Service.
You can instruct your browser to refuse all cookies or
to indicate when a cookie is being sent. However, if you do not accept cookies,
you may not be able to use some portions of our Service that cannot work
without cookies.
Examples
of Cookies we use:
(a) Session Cookies: We use
Session Cookies to operate our Service.
(b) Preference Cookies: We use
Preference Cookies to remember your preferences and various settings.
(c) Security Cookies: We use
Security Cookies for security purposes.
(d) Advertising Cookies: Advertising
Cookies are used to serve you with advertisements that may be relevant to you
and your interests.
5. Use of Data
Retrica, Inc. uses the collected data for various
purposes:
(a) to
provide and maintain our Service;
(b) to
notify you about changes to our Service;
(c) to
allow you to participate in interactive features of our Service when you choose
to do so;
(d) to
provide customer support;
(e) to
gather analysis or valuable information so that we can improve our Service;
(f) to
monitor the usage of our Service;
(g) to
detect, prevent and address technical issues;
(h) to fulfill any other purpose for which you provide it;
(i) to
carry out our obligations and enforce our rights arising from any contracts
entered into between you and us, including for billing and collection;
(j) to
provide you with notices about your account and/or subscription, including
expiration and renewal notices, email-instructions, etc.;
(k) to
provide you with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you
have already purchased or enquired about unless you have opted not to receive
such information;
(l) in
any other way we may describe when you provide the information;
(m) for
any other purpose with your consent.
6. Retention of Data
We will retain your Personal Data only for as long as is necessary for
the purposes set out in this Privacy Policy. We will retain and use your
Personal Data to the extent necessary to comply with our legal obligations (for
example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period, except when this data is used
to strengthen the security or to improve the functionality of our Service, or
we are legally obligated to retain this data for longer time periods.
7. Transfer of Data
Your information, including Personal Data, may be
transferred to – and maintained on – computers located outside of your state,
province, country or other governmental jurisdiction where the data protection
laws may differ from those of your jurisdiction.
If you are located outside United States and choose to
provide information to us, please note that we transfer the data, including
Personal Data, to United States and process it there.
If you are located inside the European Union, European
Economic Area or the United Kingdom and choose to provide information to us,
please note that we transfer the data, including Personal Data, to outside of
European Union, European Economic Area and or United Kingdom and process it
there.
Your consent to this Privacy Policy followed by your
submission of such information represents your agreement to that transfer.
Retrica,
Inc. will take all the steps reasonably necessary to ensure that your data
is treated securely and in accordance with this Privacy Policy and no transfer
of your Personal Data will take place to an organisation or a country unless
there are adequate controls in place including the security of your data and
other personal information.
8. Disclosure of Data
We
may disclose personal information that we collect, or you provide:
(a) Disclosure for Law Enforcement.
Under certain circumstances, we may be required to
disclose your Personal Data if required to do so by law or in response to valid
requests by public authorities.
(b) Business Transaction.
If we or our subsidiaries are involved in a merger,
acquisition or asset sale, your Personal Data may be transferred.
(c) Other cases. We may disclose your information also:
(i) to
our subsidiaries and affiliates;
(ii) to
contractors, service providers, and other third parties we use to support our
business;
(iii) to fulfill the purpose for which you provide it;
(iv) for
any other purpose disclosed by us when you provide the information;
(v) with
your consent in any other cases;
(vi) if we
believe disclosure is necessary or appropriate to protect the rights, property,
or safety of the Company, our customers, or others.
9. Security of Data
The security of your data is important to us but remember that no method
of transmission over the Internet or method of electronic storage is 100%
secure. While we strive to use commercially acceptable means to protect your
Personal Data, we cannot guarantee its absolute security.
10. Your Data Protection Rights Under
General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU) and
European Economic Area (EEA), you have certain data protection rights, covered
by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable steps to allow you to
correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold
about you and if you want it to be removed from our systems, please email us at
[email protected].
In
certain circumstances, you have the following data protection rights:
(a) the
right to access, update or to delete the information we have on you;
(b) the
right of rectification. You have the right to have your information rectified
if that information is inaccurate or incomplete;
(c) the
right to object. You have the right to object to our processing of your
Personal Data;
(d) the
right of restriction. You have the right to request that we restrict the
processing of your personal information;
(e) the
right to data portability. You have the right to be provided with a copy of
your Personal Data in a structured, machine-readable and commonly used format;
(f) the
right to withdraw consent. You also have the right to withdraw your
consent at any time where we rely on your consent to process your personal
information;
Please note that we may ask you to verify your identity before
responding to such requests. Please note, we may not able to provide Service
without some necessary data.
You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).
11. Your Data Protection Rights under
the California Privacy Protection Act (CalOPPA)
CalOPPA is
the first state law in the United States to require commercial websites and
online services to post a privacy policy. The law’s reach stretches well beyond
California to require a person or company in the United States (and conceivable
the world) that operates websites collecting personally identifiable
information from California consumers to post a conspicuous privacy policy on
its website stating exactly the information being collected and those
individuals with whom it is being shared, and to comply with this policy. – See
more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According
to CalOPPA we agree to the following:
(a) users
can visit our site anonymously;
(b) our
Privacy Policy link includes the word “Privacy”, and can easily be found on the
page specified above on the home page of our website or mobile application;
(c) users
will be notified of any privacy policy changes on our Privacy Policy Page;
(d) users
are able to change their personal information by emailing us at
[email protected].
Our
Policy on “Do Not Track” Signals:
We
honour Do Not Track signals and do not track, plant cookies, or use advertising
when a Do Not Track browser mechanism is in place. Do Not Track is a preference
you can set in your web browser to inform websites that you do not want to be
tracked.
You
can enable or disable Do Not Track by visiting the Preferences or Settings page
of your web browser.
12. Your Data Protection Rights under
the California Consumer Privacy Act (CCPA)
If
you are a California resident, you are entitled to learn what data we collect
about you, ask to delete your data and not to sell (share) it. To exercise your
data protection rights, you can make certain requests and ask us:
(a) What
personal information we have about you. If you make
this request, we will return to you:
(i) The
categories of personal information we have collected about you.
(ii) The
categories of sources from which we collect your personal information.
(iii) The
business or commercial purpose for collecting or selling your personal
information.
(iv) The
categories of third parties with whom we share personal information.
(v) The
specific pieces of personal information we have collected about you.
(vi) A
list of categories of personal information that we have sold, along with the
category of any other company we sold it to. If we have not sold your personal information,
we will inform you of that fact.
(vii)A
list of categories of personal information that we have disclosed for a
business purpose, along with the category of any other company we shared it
with.
Please note, you are entitled to ask us to provide you with this
information up to two times in a rolling twelve-month period. When you make
this request, the information provided may be limited to the personal
information we collected about you in the previous 12 months.
(b)
To delete your personal information. If
you make this request, we will delete the personal information we hold about
you as of the date of your request from our records and direct any service
providers to do the same. In some cases, deletion may be accomplished through
de-identification of the information. If you choose to delete your personal
information, you may not be able to use certain functions that require your
personal information to operate.
(c)
To stop selling your personal information. If
you submit a request to stop selling your personal information, we will stop
selling it. If you are a California resident, to opt-out of the sale of your
personal information, click “Do Not Sell My Personal Information” at the bottom
of our home page to submit your request.
Please note, if you ask us to delete or stop selling
your data, it may impact your experience with us, and you may not be able to
participate in certain programmes or membership services which require the
usage of your personal information to function. But in no circumstances, we
will discriminate against you for exercising your rights.
To exercise your California data protection rights
described above, please send your request(s) by one of the following means:
By
email: [email protected]
Your data protection rights,
described above, are covered by the CCPA, short for the California Consumer
Privacy Act. To find out more, visit the official California Legislative
Information website. The CCPA took effect on 01/01/2020.
13. Service Providers
We may employ third party companies and individuals to
facilitate our Service (“Service
Providers”), provide Service on our behalf, perform Service-related
services or assist us in analysing how our Service is used. These third parties
may be located out of your jurisdiction, including but not limited to your
state, province, territory, country, federation or supranational organisations
such as European Union and European Economic Area.
These third parties have access to your Personal Data only to perform
these tasks on our behalf and are obligated not to disclose or use it for any
other purpose.
14. Analytics
We
may use third-party Service Providers to monitor and analyse the use of our
Service.
Google Analytics
Google Analytics is a web analytics service offered by
Google that tracks and reports website traffic. Google uses the data collected
to track and monitor the use of our Service. This data is shared with other
Google services. Google may use the collected data to contextualise and
personalise the ads of its own advertising network.
For more information on the privacy practices of
Google, please visit the Google Privacy Terms web page:
https://policies.google.com/privacy?hl=en
We also encourage you to review the Google's policy
for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Firebase
Firebase is analytics service provided by Google LLC.
You may opt-out
of certain Firebase features through your mobile device settings, such as your
device advertising settings or by following the instructions provided by Google
in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more
information on what type of information Firebase collects, please visit the
Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
15. CI/CD tools
We may use
third-party Service Providers to automate the development process of our
Service.
GitHub
GitHub is provided by GitHub, Inc.
GitHub is a development platform to host and review
code, manage projects, and build software.
For more information on what data GitHub collects for
what purpose and how the protection of the data is ensured, please visit GitHub
Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.
Travis
CI
Travis CI is a distributed continuous integration
service to build and test projects hosted at GitHub.
For more information on what data Travis CI collects
for what purpose and how the protection of the data is ensured, please visit
Travis CI Privacy Policy page: https://docs.travis-ci.com/legal/privacy-policy.
CircleCI
CircleCI is
provided by Circle Internet Services, Inc.
CircleCI is
Continuous Integration, a development practice which is being used by software
teams allowing them to build, test and deploy applications easier and quicker
on multiple platforms.
For more information on what data Circle CI collects
for what purpose and how the protection of the data is ensured, please visit
Circle CI Privacy Policy page: https://circleci.com/privacy/.
16. Advertising
We may use
third-party Service Providers to show advertisements to you to help support and
maintain our Service.
AdMob by Google
AdMob by
Google is provided by Google LLC.
You can opt-out
from the AdMob by Google service by following the
instructions described by Google:
https://support.google.com/ads/answer/2662922?hl=en
For more
information on how Google uses the collected information, please visit the “How
Google uses data when you use our partners' sites or app” page:
http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of
Google: http://www.google.com/policies/privacy/
17. Behavioural Remarketing
Retrica,
Inc. uses remarketing services to advertise on third party websites to you
after you visited our Service. We and our third-party vendors use cookies to
inform, optimise and serve ads based on your past visits to our Service.
Google Ads (AdWords)
Google Ads
(AdWords) remarketing service is provided by Google LLC.
You can opt-out
of Google Analytics for Display Advertising and customize the Google Display
Network ads by visiting the Google Ads Settings page:
http://www.google.com/settings/ads
Google also
recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout
– for your web browser. Google Analytics Opt-out Browser Add-on provides
visitors with the ability to prevent their data from being collected and used
by Google Analytics.
For more
information on the privacy practices of Google, please visit the Google Privacy
Terms web page: https://policies.google.com/privacy?hl=en
Facebook
Facebook
remarketing service is provided by Facebook Inc.
You can learn
more about interest-based advertising from Facebook by visiting this page:
https://www.facebook.com/help/164968693837950
To opt-out from
Facebook's interest-based ads, follow these instructions from Facebook:
https://www.facebook.com/help/568137493302217
Facebook adheres
to the Self-Regulatory Principles for Online Behavioural Advertising
established by the Digital Advertising Alliance. You can also opt-out from
Facebook and other participating companies through the Digital Advertising
Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising
Alliance of Canada in Canada http://youradchoices.ca/ or the European
Interactive Digital Advertising Alliance in Europe
http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more
information on the privacy practices of Facebook, please visit Facebook's Data
Policy: https://www.facebook.com/privacy/explanation
18. Payments
We may provide paid products and/or services within
Service. In that case, we use third-party services for payment processing (e.g.
payment processors).
We will not
store or collect your payment card details. That information is provided
directly to our third-party payment processors whose use of your personal
information is governed by their Privacy Policy. These payment processors
adhere to the standards set by PCI-DSS as managed by the PCI Security Standards
Council, which is a joint effort of brands like Visa, Mastercard, American
Express and Discover. PCI-DSS requirements help ensure the secure handling of
payment information.
The
payment processors we work with are:
PayPal or Braintree:
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
Apple Store In-App
Payments:
Their Privacy Policy can be viewed at:
https://www.apple.com/legal/privacy/en-ww/ / https://support.apple.com/en-us/HT203027
Google Play In-App
Payments:
Their Privacy Policy can be viewed at:
https://policies.google.com/privacy?hl=en&gl=us /
https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
Stripe:
Their Privacy Policy can be viewed at:
https://stripe.com/us/privacy
Adyen:
Their
Terms and conditions can be viewed at https://www.adyen.com/legal/terms-and-conditions.
Alipay:
Their Privacy Policy can be viewed at:
https://render.alipay.com/p/f/agreementpages/alipayglobalprivacypolicy.html
Square:
Their Privacy Policy can be viewed at:
https://squareup.com/us/en/legal/general/privacy
WePay:
Their Privacy Policy can be viewed at:
https://go.wepay.com/privacy-policy
WeChat:
Their Privacy Policy can be viewed at:
https://www.wechat.com/en/privacy_policy.html
19. Links to Other Sites
Our Service may contain links to other sites that are
not operated by us. If you click a third-party link, you will be directed to
that third party's site. We strongly advise you to review the Privacy Policy of
every site you visit.
We have no
control over and assume no responsibility for the content, privacy policies or
practices of any third-party sites or services.
20. Children's Privacy
Our
Services are not intended for use by children under the age of 18 (“Child”
or “Children”).
We do
not knowingly collect personally identifiable information from Children under
18. If you become aware that a Child has provided us with Personal Data, please
contact us. If we become aware that we have collected Personal Data from
Children without verification of parental consent, we take steps to remove that
information from our servers.
21. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We
will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service,
prior to the change becoming effective and update “effective date” at the top
of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are posted on
this page.
22. Contact Us
If
you have any questions about this Privacy Policy, please contact us:
By email: [email protected].