Gadget Flow Privacy Notice
Last Revised: October 26th 2018
Our commitment to Privacy
Protecting your privacy and your information is a top priority here at Gadget Flow Inc. (“Gadget Flow” “we”, “us” or “ours”). This Privacy Notice explains what information we collect from website visitors and users of our services (“You”), how we use it, who we share it with and how we protect it.
Please note that your access to our Services and Website may be subject to certain third party terms and conditions and privacy policies, including but not limited to third-party online storage services and payment providers. Unless stated otherwise, this Privacy Notice only deals with the use of information collected by Gadget Flow. You acknowledge that Gadget Flow is not responsible for any such third party terms and conditions and their use of your information.
This Privacy Notice should be read alongside our TOU. Capitalized terms in this Privacy Notice have the meanings as set forth in our TOU.
The Federal Trade Commission (FTC) has jurisdiction over Gadget Flow’s compliance with the EU-U.S. Privacy Shield.
If you are under 16 years of age you must obtain parental consent before using the Website.
What information do we collect and what do we use it for?
The information that we collect about you will depend on whether you are a User or a Customer of ours.
Only registered Users may access the special features of our Services (exclusive discounts, deals and custom feed features). You can register through our Website or through our iOS or Android Apps. During the registration process, you will provide us with the following information:
- Your First name
- Your Email Address
- Your Password
- Your Favorite Product Categories
Only registered Customers can post their Products on our Platform. You can register through our Website by filling in a registration form. During the registration process, you have to provide us with the following information:
- Your full name
- Your e-mail
- Your Product title
- Your Product link
- Your Product description
- You will be asked to provide further the following information:
- Photos of your Product
- A video of your Product
The purpose of our request of this additional information is promote your Product to our Users via the website and social media.
Users and Customers have the obligation to state truthfully, accurately and fully your up-to-date information in the registration process. If your information is not in compliance with these provisions or if Gadget Flow has reasonable suspicions that your information is not in accordance with these provisions, Gadget Flow has the right to reject your application for registration or to suspend or terminate immediately your Account without prior notice. You agree that you have no right to any compensation for the rejection of your application.
Activity and behavior information: We collect information about your activity and behaviour on the Website, such as your posts of any kind and/or the Products that you submit. We also collect our Visitors’ and Users’ reviews about you.
Posted Comments: Should you choose to add a comment to any posts that we have published on our Website or blog, your name and email address will be saved to the Website’s database, along with your computer device’s IP address as well as the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post. Only your name will be shown on the Website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed. Your comments and any associated personal data will remain on the Website until we decide to 1) remove the comment or 2) remove the blog post.
NOTE: You are advised to not enter personally identifiable information in the actual comment field of any blog post comments that you submit on our Website.
Correspondence information: If you send us personal correspondence, such as emails or letters or third parties send us correspondence about your activities or postings on our Website, we may store such information in our servers.
Website visitation tracking: Our Website uses google analytics (“GA”) to track our Users’ interaction. We use the data to determine the number of people using our Website, to better understand how they locate and use our web pages. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to Gadget Flow. GA also records your computer device’s IP address which could be used to personally identify you but Google do not grant us access to this.
Contact forms and email links: Should you choose to contact us via the contact form at our contact us page or an email link, none of the data that you provide will be stored in the Website or passed to / be processed by any of the Third Party Data Processors. The data will be compiled into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (also known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography. The email content is then decrypted by our local computers and devices.
Newsletters: If you are a registered user at our Website, you may receive daily or weekly newsletters from us. If you subscribe to our newsletter, your e-mail address will be forwarded to Campaign Monitor, a third party, for marketing purposes. Your e-mail address shall be saved in Campaign Monitor’s database for as long as we continue to use Campaign Monitor’s services for marketing purposes. You may request removal of your e-mail address from Campaign Monitor’s list. You can do this by using the unsubscribe links included in our newsletter.
Other uses of your information: In addition to the purposes listed above, we may also use your information as follows:
- in order to resolve disputes;
- troubleshoot problems;
- help promote your Product;
- measure consumer interest in Services;
- inform you about offers, products, services, and updates;
- customize your experience;
- detect and protect us against error, fraud and other criminal activity;
- enforce our TOU; and as otherwise described to you at the time of collection.
- At times, we may look across multiple Customers to identify problems or resolve disputes, and in particular we may examine your information to identify Users using multiple usernames or aliases. We may compare and review your information for errors, omissions and for accuracy.
- We may use Users’ information in order to provide benchmark analysis and aggregate statistics to Customers based on the performance of their Products. This particular information will be anonymized, will not contain personal identification and will not be transferred or sold to third parties in any way or format that identifies you.
Note: We do not transfer, sell or rent your information to third parties for their marketing purposes other than what is stated in this Privacy Notice. We request only the information that we need to operate our Services and improve our Website’s user experience. We do not use your information to create any advertising creative.
Who do we share your personal information with?
We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
Except as otherwise provided herein, Gadget Flow discloses personal information only to third parties who reasonably need to know such personal information only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
Gadget Flow may provide personal information to third parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Gadget Flow may store such personal information in the facilities operated by third parties. Such third parties must agree to use such personal information only for the purposes for which they have been engaged by Gadget Flow and they must either:
- comply with the EU-U.S. Privacy Shield principles or another mechanism permitted by the applicable EU data protection law(s) for transfers and processing of personal information;
- or agree to provide adequate protections for the personal information that are no less protective than those set out in this Privacy Notice.
Gadget Flow has responsibility for the processing of personal information it receives under EU-U.S. Privacy Shield and subsequently transfers such personal information to such third parties, acting as an agent on its behalf. Gadget Flow is liable if such third parties, acting as its agent on its behalf, process such personal information in a manner inconsistent with EU-U.S. Privacy Shield principles and this Privacy Notice.
How do we protect your information?
– Customers understand and agree that their information can be accessed by the Visitors and Users of our Website. Although Gadget Flow makes reasonable efforts to restrict access to the above mentioned information only to our registered Users, Gadget Flow can not guarantee that other third parties will not, without Gadget Flow’s consent, gain access to it.
– You may ask Gadget Flow to remove your Product from the Website and thus disable access to your information by Visitors and Users at any time. However, you acknowledge that the Visitors, Users and other parties who have previously gained access to your information may have retained a copy. Gadget Flow is not responsible for the retention, use or violation of privacy of that information in those instances, or for the use or privacy of that information by any of such parties while it is available on our Website.
– All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.
– We do not make any of your information available to third parties for their marketing purposes. Gadget Flow’s software runs on individual servers and no data given or collected is shared with other social media platforms. If however, we share your information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.
– Gadget Flow uses robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your information, using both server authentication and data encryption. These technologies help ensure that your information is safe, secure, and only available to you and to whom you have granted access. Gadget Flow also implements other advanced technology measures to prevent interference or access from outside intruders.
– All traffic (transferral of files) between the Website and your browser is encrypted and delivered over HTTPS.
– We do not tolerate Spam. To report Gadget Flow-related spam please contact us at [email protected] You may not use our communication tools to send spam or otherwise send content that would violate our TOU. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.
– Gadget Flow does its utmost to secure communications and data storage in order to protect confidentiality of your information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.
Cookies and similar tracking technology
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting 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.
Your data protection rights
Depending on where you reside, You may have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “Contact Us” heading below.
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contact Us” heading below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
International data transfers
Gadget Flow is a United States (US) headquartered company. If you are located outside the US and choose to provide information to us, Gadget Flow transfers your information to our servers in the US. The US may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the US, we will protect it as described in this Privacy Notice. By visiting our Website or providing Gadget Flow with your information, you acknowledge to this transfer, processing and storage of your information in the US.
We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.
Legal basis for processing personal information (EEA Users and Customers only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate and we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” heading below.
Links to Other Sites
Our Website contains links to other websites that are not owned or controlled by Gadget Flow. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Website and to read the privacy policies of each and every website that collects personal information. This privacy Notice applies only to information collected by this Website.
The data controller of this website is: Gadget Flow Inc, a Delaware Corporation.
229 Wynsum Ave, Merrick
Changes to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. You can see when this Privacy Notice was last updated by checking the “Last Revised” date displayed at the top of this Privacy Notice.
Independent Dispute Mechanism
In compliance with the EU-U.S. Privacy Shield Principles, Gadget Flow commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their personal data should contact us at: [email protected]. If a Customer’s question or concern cannot be satisfied through this process we have further committed to refer unresolved privacy complaints under EU-U.S. Privacy Shield to an independent dispute resolution mechanism operated by JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Gadget Flow, EU individuals may bring a complaint before JAMS Privacy Shield program can be found at: http://www.jamsadr.com/eu-us-privacy-shield. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. Gadget Flow commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
Gadget Flow complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Gadget Flow has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield principles, the Privacy Shield principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.