We also state your rights to corrections and erasure.
A. What Personal Data Do We Collect From You?
Personal data is information that can be used to identify you such as your name, IP address, and email address. We process personal data from you in a number of ways including:
- Purchases: Your name, email address, and credit card information although we use third parties (PayPal, Skrill and Clickbank) to collect and process this data.
- Log in: Your name, email address, and password when you log in to your account.
- Customer Service: Your name, email address, and reason for contacting us.
B. What Is The Purpose of Processing Your Personal Data?
We collect the information above for the following purposes.
- Purchases: Your personal data is used to process payment and provide you with Back the Draw membership.
- Log in: Your personal data is used to provide access to your account.
- Customer Service: Your personal data is used to evaluate your inquiry and provide you with answers.
C. What Legal Basis Do We Have For Collecting and Processing Your Information?
Websites must have a legal basis for collecting information from individuals located in the European Union. Our legal basis for each of the ways we process your data is as follows.
- Purchases: We process your data as part of an allowed contractual transaction.
- Log in: A legitimate interest exists for allowing you to access your account. We consider the processing of your login information a legitimate interest because when you seek to login, you expect us to collect information to allow you access to the system and we have a legitimate interest in allowing customers access to their accounts.
- Customer Service: A legitimate interest exists for providing you with answers to your questions. When you affirmatively contact us, your expectation is we will use your personal data to reply with an answer and we have a legitimate business interest in providing customers and potential customers with answers to their questions.
D. Who Has Access To The Data We Collect?
We process and access you data as described above through the help of third parties that have the digital infrastructure that we do not and without whom we would be unable to provide Back the Draw memberships including:
- PayPal and Skrill for processing transactions;
- GetResponse for email and customer management;
- Google Analytics for site statistics so we can analyze how people use our site.
These third parties have made contractual promises to not use your personal data in any manner we do not authorize.
E. Cookies and Similar Technologies
F. How Long Do We Keep Your Data?
We keep your personal data for different periods of time depending on the reason it was gathered in the first place.
- Purchases: We keep your payment data via a third party process for as long as you continue to be a paid member of Back the Draw. Once this is no longer the case, we will hold your information for an additional seven years as part of our tax records should an audit arise.
- Login: We will maintain your login data for as long as you are a paying member of Back the Draw.
- Customer Service: We will hold customer service personal data for a period of four years which covers the statute of limitations should a legal dispute arise between you and us.
G. Your Right To Ask For Corrections, Erasure, And Other Actions
We want you to have control over your data. You have the right to see all the data we have for you, ask for the corrections to the data, ask us to erase the data, object to how we use your data, ask that the data be exported, and ask that we stop automatically processing the data in particular manners. Although we have certain rights to limit your control of data, we believe it is YOUR data so we will liberally comply with your requests whenever possible. We are not a data mining company trying to monetise your personal information. To exercise any of these rights, please contact us.
H. Your Right To Withdraw Consent
We want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. You can contact us here.
J. Legal Disclosures of Personal Information
We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site.
K. DMCA Disclosures
We comply with the Digital Millennium Copyright Act of 1998. As part of the compliance process, we may be required to disclose whatever information we have for you to a copyright holder who has submitted a complaint to us as a matter of law.
L. Security Measures
We have security measures in place such as Secure Sockets Layer protocols to prevent the loss, misuse, and alteration of the information that we or our vendors obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration. If we suffer a data breach, we will provide you with the appropriate breach notification.
M. Third Party Websites
We link to other sites, but please keep in mind that we do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.
N. Sale of Business
Should we sell this site or our business, your personal information will be an asset transferred to the new owner.