Collection and Retention of Personal Information
GPW collects various types of information (“personal information” or “information”), such as:
· Voluntarily provided information, which may include:
· general account and registration items such as your name, user name, address, telephone number, email address, and other account identifiers;
· transaction, order fulfillment and experience information which may be used when you purchase products or services, and for delivery of requested products and services, such as billing and/or credit card information, details about other financial instruments used in a transaction, amounts paid, sent and/or received, device information, technical usage data and geolocation data;
· information automatically collected when visiting GPW sites or using GPW services, which may include information derived by plugins, cookies, server logs, and other tracking or similar technologies. See Attachment C to this Agreement, Cookies and Similar Tracking Technologies;
· information collected by GPW related to your use of the GPW sites and services, which may include additional information from or about you when you communicate with GPW; and
· Other information as more fully described on Attachment A to this Agreement, Collected Information.
GPW only collects personal information consistent with the provisions in this Agreement. It is the Site Owner’s intent to use personal information only for the purpose(s) for which it was requested, additional purposes specifically provided or described by GPW, and the purposes described on Attachment B to this Agreement, Usage of personal information.
GPW may have the occasion to collect anonymous demographic information such as age, gender, household income, political affiliation, race and religion at a later time. The Site Owner may also gather information about the type of browser, IP address or type of operating system you are using to assist in providing and maintaining superior quality service. See Collected Information, Attachment A of this Agreement for more details.
Use of Information Collected by GPW
The Site Owner does not now, nor will it in the future, sell, rent or lease any of its customer lists and/or names to any third parties. However, GPW may collect and may make use of personal information to assist in the operation of GPW and to ensure delivery of the services you need and request. At times, the Site Owner may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from GPW. GPW may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future products or services that may be offered. Further, GPW may deem it necessary to follow websites and/or pages published by GPW that GPW users may frequent in an effort to glean what types of services and/or products may be the most popular to customers or the general public.
GPW may disclose your personal information without prior notice to you only if:
(a) required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
i. Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process which may be served upon GPW and/or the Site Owner;
ii. Maintain, safeguard and/or preserve all the rights and/or property of GPW and/or the Site Owner; or
iii. Take action under extraordinary circumstances in an effort to safeguard the personal safety of users of GPW and/or the general public; and/or
(b) otherwise in accordance with Attachment B to this Agreement, Usage of Personal Information.
Partners, Allies and Affiliates (“Affiliates”)
GPW engages, coordinates and is affiliated with various partners, allies and affiliates (“Affiliates”) who assist GPW in GPW’s operations, including the provision of products and services and in improving and marketing GPW’s products and services. The Affiliates may provide you products or services in connection with GPW’s operations and, with your consent, send marketing or promotional material to you. Also, GPW may work jointly with the Affiliates in providing you products or services and may share your information with the Affiliates for purposes of marketing or promotions. In cases where an Affiliate cooperates with GPW in providing you products or services, it may be necessary or useful for GPW to share information related to the transaction with the Affiliates as a means of facilitating the transactions relating to the products or services. In these cases, GPW either has a legitimate interest in sharing and processing the information or deems the use of the information to be necessary for the provision of the ordered products or services. With respect to marketing, promotions, advertising and the sharing of your information for such purposes, GPW and the Affiliates rely upon your consent, which you may withdraw at any time.
GPW uses great care in ensuring that the information such Affiliates receive is limited to that which is necessary for the Affiliates to perform the functions for which they have been engaged, and the Affiliates are legally bound not to use such information for other purposes. In some cases, the services provided by the Affiliates are essential for GPW to provide its customers the products and services they require, including payment processing, shipping, operations and security. Other efforts and undertakings of the Affiliates are not strictly necessary for the provision of GPW’s products and services but are valuable to GPW in its mission to improve its operations; in such cases, GPW has a legitimate interest in working with the GPW Affiliates to facilitate and improve operations.
Third Parties in General
GPW does not control the privacy, information or security policies of the Affiliates or Third Parties, who may have different practices with respect to the use and disclosure of information you provide them. GPW is not responsible for the privacy or security practices of the Affiliates or Third Parties, even those linked to or on the GPW sites. The Site Owner neither claims nor accepts responsibility for any practices and/or procedures of other such websites, to the fullest extent permitted by applicable law.
The Site Owner encourages you to read the privacy policies, cookie statements and similar agreements or disclosures provided by the respective Affiliates and Third Parties and ask them questions before disclosing your personal information to them.
For the purposes of the General Data Protection Regulation, such Affiliates and Third Parties are independent controllers and/or processors of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with your usage of the GPW sites.
Examples of Third Parties include:
· Facebook: GPW uses Facebook to advertise and market the GPW products and services and for other GPW operations. To learn more about how Facebook uses your data please visit their Data Policy or log on to your Facebook account and access your settings. To understand more about Facebook advertising go here.
GPW may share your information with the Affiliates for purposes of marketing or promotions. In cases where a Third Party cooperates with GPW in providing you products and services, it may be necessary or useful for GPW to share information related to the transaction with the Third Party as a means of facilitating the transactions relating to the products or services. In these cases, GPW either has a legitimate interest in sharing and processing the information or deems the use of the information to be necessary for the provision of the products or services. With respect to marketing, promotions, advertising and the sharing of your information for such purposes, GPW and the Third Parties rely upon your consent, which you may withdraw at any time.
Third Party Technologies
The Affiliates and Third Parties may acquire information about you and your usage of their sites by means of various technologies such as plugins (including “Like” or “Send” buttons), cookies, and other tracking or similar technologies. While GPW selects or approves these third-party technologies which are placed on or otherwise interactive with the GPW sites, the technical processes and interactions of those technologies are governed by the privacy policies, cookie statements and similar agreements or disclosures provided by the respective Third Parties. These technologies, which may allow a Third Party to recognize your computer or mobile device when you access or use the GPW sites, are deployed for customized online advertising and other marketing and promotions purposes. For more information, see Attachment C. Cooking and Similar Tracking Technologies. GPW and the Third Parties rely on your consent in their deployment and usage of plugins, cookies, and other tracking or similar technologies for advertising, marketing and promotions purposes.
Use of Information Collected by GPW’s Affiliates and Third Parties
The Affiliates and Third Parties may collect and may make use of personal information for purposes similar to those for which GPW collects and uses information.
The Affiliates and Third Parties may disclose your personal information without prior notice to you only if:
(a) required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:
i. Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any process which may be served upon the Affiliates and/or Third Parties;
ii. Maintain, safeguard and/or preserve all the rights and/or property of the Affiliates and/or Third Parties; or
iii. Take action under extraordinary circumstances in an effort to safeguard the personal safety of users of the Affiliates, Third Parties and/or the general public; and/or
(b) otherwise in accordance with Attachment B to this Agreement, Usage of Personal Information.
Unsubscribe or Opt-Out
All users and/or visitors to GPW have the option to discontinue receiving communication from the Site Owner and/or reserve the right to discontinue receiving communications by way of email or newsletters. To discontinue or unsubscribe to GPW (or any of the GPW sites) please send an email with UNSUBSCRIBE in the subject field to firstname.lastname@example.org. If you wish to unsubscribe from or opt-out of any Affiliate or Third Party website(s)s, you must go to that/those specific website(s) to unsubscribe and/or opt-out.
Other Choices You Have Regarding Your Information
The following are some additional principles and considerations about your options relating to your personal information:
· You may decline to give your information when it’s requested, but some or all of GPW’s services may not be available to you.
· The hardware device you use to access the GPW sites and services may collect information about you, including geolocation information and usage data that GPW may then collect and utilize. The settings options for your hardware device may allow you to restrict the collection and use of such information.
· Although GPW does not serve you advertising using ad-related cookies and web beacons., some of the Affiliates and Third Parties may do so. You may be able to opt-out of such advertising-related cookies and web beacons to terminate such advertising; however, you may continue to see such advertising on Affiliate and Third Party websites. For more information on Affiliate and Third Party advertising-related cookies and customized online (or interest-based) advertising, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit About Ads. Additionally, you may opt-out of tracking and receiving customized online (or interest-based) advertisements, delivered to your mobile device and generated by some mobile advertising companies and other similar entities, by downloading the App Choices app or similar software.
· Most browsers and internet connective hardware allow you to manage your cookies preferences, including the abilities to delete, disable, or block certain cookies and other tracking technologies. For more information, visit allaboutcookies.org. If you delete, disable or block certain cookies, you may lose the ability to engage the GPW, Affiliate and/or Third Party sites as you wish and lose access to important features and functions.
· For more information about cookies, see Attachment C. Cookies and Similar Tracking Technologies.
· If you have an account with GPW or its Affiliates, you generally may review and edit your personal information by logging in and updating the information directly or by contacting GPW or the Affiliate. Direct review and edit of personal information by users is not currently available for GPW’s sites but may become so in the future.
· GPW may send you marketing content about GPW’s services and sites, including services and products GPW jointly offers with the Affiliates and Third Parties by various means, including email newsletters. In most cases, you may opt-out of these communications by following the included instructions.
· GPW may send you communications that are required or necessary for users of GPW’s services and sites to have, and other communications that you may request from GPW. Opting-out of these communications is not possible; however, you may be to adjust the settings in the media, format and hardware through which you receive these notices.
For additional data protection rights, see Attachment D to this Agreement, Other Data Protection Rights.
GPW endeavors to take every precaution to maintain adequate physical, procedural and technical security with respect to the Site Owner’s and GPW’s offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of the personal information under its control.
Payments and Shipping
GPW and their Affiliates encrypt payment information and certain other information, including credit card, bank account and similar items using secure socket layer technology (“SSL”). While GPW and their Affiliates are very careful in their use of such information, no transmission of electronic data via the internet or other digital service is absolutely secure and it is therefore not possible to guarantee the complete security of such information.
Transaction information from credit card users who purchase products or services from GPW may be received by Affiliates or Third Parties such as Amazon, Etsy, Square, Stripe, or PayPal. Such information generally includes credit or debit card number, bank account information, purchase amount, and date/time of purchase.
While conducting fraud monitoring, prevention and detection activities, such Affiliates or Third Parties may also receive information about you from their business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country); such information is essential for such Affiliates and Third Parties to confirm the purchaser identity and generally prevent fraud. Such fraud monitoring, detection and prevention measures may employ technology that assists them in evaluating the risk of an attempted transaction enabled on a GPW site or the application that collects information from the prospective purchaser.
GPW reserve the right to update and/or change the terms of this Agreement; the Site Owner will post those change to GPW’s homepages so that users and/or visitors always have notice of and access to the type of information GPW collects, how it will be used, and under what circumstances, if any, GPW may disclose such information. If at any point in time GPW or the Site Owner decide to make use of any personally identifiable information on file, in a manner substantially different from that which was stated when this information was initially collected, the affected user or users shall be promptly notified by email. Users at that time shall have the option as to whether or not to permit the use of their information in this separate manner.
Acceptance of Terms
How to Contact Us
If you have any questions or concerns regarding this Agreement, contact the Site Owner at the following email, telephone number or mailing address.
All of the attachments, schedules and exhibits referred to in this Agreement are a part of this Agreement, and all are hereby incorporated herein by reference.
ATTACHMENT A. Collected Information
The personal information that GPW, Affiliates and/or Third Parties may collect includes:
(i) User-Provided information: as a user you may provide to GPW personal information when you sign up, register, consult with the Site Owner or agents, employees or staff of GPW, telephonically contact GPW, electronically and/or wirelessly contact GPW, including via fax, email or text/SMS services, integrate products or services provided by GPW with other websites or services (including online payment, e-commerce, online subscription, email and online marketing services), or communicate with GPW in any other way.
Prior to collecting your personal information GPW will indicate whether the personal information is necessary for the use of GPW, or for the provision of the products and services you request, or is entirely optional, as well as explain the consequences, if any, of your decision not to provide the personal information. Your act of providing the personal information means that you agree to its collection, use and disclosures by GPW as described in this Agreement and as may be necessary or useful for the provision of the services and products you request.
User-Provided personal information may include:
· registration information (information typical for creating a website usage account, such as name, email address, username, password, company name, occupation, location, and phone number);
· billing and communications information (generally this consists of credit card details, billing address and security identifiers/authenticators). GPW may also maintain a record of your billing transactions and purchases, and any communications and responses pertaining to same for a reasonable period of time; and
· information provided for the provision of services or products (this will include any personal information you disclose or cause to be disclosed to GPW in order to receive services or products of a unique or customized character, which information will be collected, used and processed in accordance with your instructions and GPW’s customary practices for receiving and handling such information).
Automatically-collected information may include:
· device information (information about the device and applications you use to access the respective sites or purchase products or services, including your IP address, your operating system, your browser ID, and other information about your system and connection);
· log data: the web servers of GPW, Affiliates and/or Third Parties may create log files that record data each time a device accesses those servers, which log files may contain data about the nature of each access, including originating IP addresses. GPW, Affiliates and/or Third Parties may also access metadata and other information associated with files that their users upload; and
· product usage data: GPW, Affiliates and/or Third Parties may collect usage data of users who interact with them, which may include dates and times of access and browsing activities, and may also collect information regarding the provision of products and services you request. This information enables GPW, Affiliates and/or Third Parties to improve the site content and the provision of products and services, and facilitates research and analysis pertaining to the services and products offered on GPW, Affiliates and/or Third Parties.
iii) Third-Party Source information: from time to time, GPW may obtain information about you from Affiliates or Third Parties such as public databases, social media platforms, third-party data providers, GPW’s strategic allies and other persons or entities engaged by the Site Owner as joint marketing partners. The Site Owner takes measures to ensure that such Affiliates and/or Third Parties are legally or contractually permitted to disclose such information to GPW.
Affiliate and Third-Party Source information may include:
· demographic information (gender, age, education, lifestyle, etc.);
· device information (IP addresses, unique device identifiers, etc.);
· location (region, city, state, country, etc.); and
· online behavioral data (information about users’ usage of social media, page view information, search results, links, etc.).
Such Affiliate and Third Party source information may be used alone or in combination with other information to enhance the ability of GPW, the Affiliates and/or Third Parties to provide relevant marketing and content to users and to develop and provide such users with more relevant products, features, and services.
The use by GPW, the Affiliates and/or Third Parties of automatically-collected and third-party source information may include information received from or collected by MailChimp, other Affiliates and/or Third Parties. Their collection and use of such personal information is described on their respective privacy policies, disclosures and similar documents.
ATTACHMENT B. Usage of Personal Information
In addition to the purposes described under Use of information Collected by GPW, above, GPW may collect and use personal information for the following purposes:
· Billing and collecting money you owe to GPW (including the sending to you of emails, invoices, receipts, notices of delinquency, and requests for credit card or billing information). GPW uses Third Parties for secure credit card transaction processing, which Third Parties may collect billing information to process your orders and credit card payments;
· Customer support communications (including answering questions you may have about current or future products or services, past orders, etc.);
· Enforcement of compliance with GPW’s agreements and applicable law (including the development of protective tools and algorithms);
· Protection of the rights and safety of GPW’s users and third parties (including the development of protective tools and algorithms);
· Compliance with law and other legal requirements (including court orders, valid discovery requests and subpoenas, and other appropriate legal matters and processes);
· Provision of information to GPW’s representatives and advisors (including accountants, consultants and attorneys for financial, accounting, legal, tax, security and other legitimate business reasons);
· Prosecution and defense in legal proceedings (including court, ADR, mediation, arbitration and similar proceedings);
· Response to lawful requests or demands by governmental authorities (including for national security or law enforcement purposes);
· Provision, support and improvement of GPW’s services and products (including the sharing of your information with third parties in order to facilitate and/or improve GPW’s provision of products and services to you, or to make certain products or services available to you);
· Provision of suggestions, advice or instructions to you pertaining to products or services you obtain from GPW or other matters pertaining to your usage of GPW;
· Data analytics usage (including the use of your personal information in data analytics projects designed to assist GPW in providing and improving their services, such as user access, browsing data, purchase history, etc.);
· Legitimate business reasons and other lawful purposes, in general.
In addition to the purposes described under Use of information Collected by GPW’s Affiliates and Third Parties, above, the Affiliates and Third Parties may collect and use personal information for the following purposes:
· Site operation and provision of their services, which may include: payment sending, requesting, initiation, and/or account depositing; authenticating account access; communicating with you about your account, their sites and/or services; account creation and account connections with third-party accounts, sites or platforms; evaluating creditworthiness and other financial standing checks, reviewing applications and performing accuracy and verification checks/analyses;
· Provision of personalized services provided by their third party websites and online services, including: presenting a targeted display, feature or offer to you on their third party websites; using cookies and other tracking technologies to provide such online services and/or work with their third parties (for example, internet advertising and analytics companies);
· Marketing and delivery of marketing materials related to their products and services, or the products and services of their affiliates and unaffiliated third parties engaged for business reasons;
· Simplifying users’ locating and connecting with others, including suggesting connections to others, and similar social functionality and features intended to simplify users’ interaction with the sites and services;
· Provision of location-specific options, functionality or offers to users who choose to share their geolocation information, including the enhancement of site and services security and provision of location-based services, such as search results, advertising and other personalized content;
· Management of their operational needs, such as monitoring, analyzing, and improving their services and site performance and functionality;
· Risk management and protection of sites and services by means of user identity verification, and detection and prevention of fraud and abuse;
· Customization of their sites and services in order to better meet your needs, increase your satisfaction and appeal to your interests;
· Compliance with their contractual and legal obligations, and enforcement of their rights pertaining to their sites and services; and
· Customer service outreach, response and general performance.
Sharing Your information
Generally, GPW may share your personal information for the following purposes and reasons:
· With other members of the GPW family, Affiliates and/or Third Parties for the provision of the products and services you request, risk management, fraud and abuse detection and prevention, and technical reasons to ensure GPW’s operations.
· With Third Parties who GPW engages in connection with GPW’s operations, including shipping service providers, security services, payment processors, marketers acting on GPW’s behalf, and general operational and/or customer support.
GPW may share your personal information with Affiliates and Third Parties for GPW’s legitimate business purposes or as permitted or required by law, including:
· When it’s necessary for GPW to comply with a law, legal process or regulations;
· When GPW determines, in its sole discretion, that the disclosure of your information is necessary or appropriate to prevent physical harm or financial loss or protect other vital personal interests, or in connection with an investigation of suspected or actual illegal activity;
· When GPW investigates its own legal rights and obligations pertaining to its services or operations, or otherwise finds such sharing is necessary to GPW’s property, operations and interests;
· When GPW chooses to facilitate a sale or purchase of all or part of GPW’s business or operations, or in connection with any other form of merger, acquisition, combination, or other consolidation;
· For shipping and delivery of goods you have requested;
· For GPW’s risk assessment and management measures, fraud detection and prevention measures, including fraud that occurs at or involves the Affiliates or Third Parties;
· For GPW’s banking and financial matters;
· For GPW’s audit, compliance, and corporate governance functions.
GPW may share your information with your consent or at your direction, including if you authorize an account connection with an Affiliate or Third Party account or platform.
Further, GPW may provide aggregated statistical data to Affiliates or Third Parties, including other businesses and members of the public, about how, when, and why users engage the GPW sites and use GPW’s services. Such information will not personally identify you or make you identifiable or provide specific information about your use of the sites or services.
GPW does not share your information with Affiliates or Third Parties for their marketing, advertising or promotional purposes without your consent.
ATTACHMENT C. Cookies and Similar Tracking Technologies
Cookies are small data files that are stored on your hardware’s device memory, such as your computer, smartphone or tablet, when you visit a website of, or view a message sent by, GPW, its Affiliates or Third Parties. Certain cookies will persist in your device memory only for the duration of your web or application session and terminate when you close your browser or exit the application; other cookies serve to identify you when you return to a site previously visited or otherwise access or use the services of GPW, its Affiliates, or Third parties, and thus have a longer life in your device memory. Cookies serve a variety of functions, including registration support and integrity, retention of account settings and user preferences, and evaluation and compilation of user activity statistics. For more information and to learn how to block or delete cookies used in the Services, please visit your web browser’s security and privacy notices and agreements.
Cookies and similar technologies may acquire the following information from you:
i) Browser and device data, including: device type; IP address; browser type; operating system; screen resolution; operating system name, version and type; device manufacturer and model; language; plug-ins; add-ons; and the language version of the pages you visit;
ii) Usage data, including: the time you spend on the sites; the pages you visit; the links you clicked; your language preferences; and the pages that led or referred you to the respective sites;
iii) Other information, including a history of your online activities on websites and connected devices across Third-Party and Affiliate sites, devices, apps and other online features and services. GPW and its Affiliates and Third Parties may use Google Analytics on their sites for various kinds of analysis and for technical diagnostic issues.
GPW, the Affiliates and Third Parties also may utilize web beacons to collect information. Web beacons are electronic images that may be used in the provision of services and in emails sent to you by GPW, Affiliates and/or Third Parties. They are used to deliver cookies, track user site visits and app usage, analyze and interpret customer usage and marketing campaign effectiveness, and learn when an email has been opened and acted upon.
Cookies, web beacons and similar technologies may be used for the following purposes:
a) Collection of anonymous statistical information about user activity such as session length and location of access in order to assess user satisfaction, user needs and desires and generally improve the provision of products and services;
b) Collection of data about your interaction with GPW, including for the purposes of improving GPW’s marketing, advertising and promotion, which may entail the forwarding of such information to the Affiliates and Third Parties;
c) Facilitation of the collection of data by Affiliates or Third Parties about your interaction with sites and services other than those of GPW;
d) Detecting unique visitors and identifying return visitors so that capacity and resources remain sufficient to meet the demand for products and services;
e) Enabling the Affiliates and Third Parties to use these tracking technologies to track your behavior on GPW’s behalf on GPW’s sites across various devices you may use and on the Affiliate sites;
f) For the customization of your online experience, your use of services provided by GPW, the Affiliates and/or Third Parties, and other online content and advertising;
g) Risk mitigation, fraud prevention, and promotion of trust and safety across the sites and in connection with the services of GPW, its Affiliates and Third Parties; and
h) Design, enhancement and customization of the GPW sites, including promotional layout and substantive content.
Most commercially sold web and mobile device browsers by default will accept cookies and similar technologies. However, users can generally change browser settings to prevent the automatic acceptance of cookies, and in many cases require a notification before a cookie is set. Many browsers enable users to block cookies on different types of browsers and mobile devices. However, understand that by blocking or deleting cookies used in the services of GPW, the Affiliates and/or Third Parties, the level and quality of service may be diminished.
ATTACHMENT D. Other Data Protection Rights
You have the following data protection rights:
To access, correct, update or request deletion of your personal information: GPW takes reasonable measures to ensure that collected data is reliable for its intended use, accurate, complete and not out of date.
In addition, individual users of GPW who are in the European Union (“EU”) have the following data protection rights:
· You can object to the processing of your personal information, ask to restrict processing of your personal information or request its portability. Users in the EU can exercise these rights by contacting the Site Owner at email@example.com.
· Similarly, if personal information is collected or processed on the basis of your consent, you may withdraw your consent at any time. Withdrawing your consent won’t affect the legality of any processing conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
· Finally, you have the right to complain to a data protection authority about the collection and use of personal information. For more information, please contact your local data protection authority.
GPW answers all requests from individuals choosing to inquire about or exercise their data protection rights in accordance with applicable data protection law, subject to such individuals’ verification of identity.
ATTACHMENT E. AFFILIATES AND THIRD PARTIES
The following is a non-exclusive list of GPW’s Affiliates and Third Parties.