PRIVACY NOTICE
Last updated June 9, 2021
Thank you for choosing to be part of our community at WebSafety Ninja Company.
When you visit our website websafety.ninja (the "Website"), and more generally, use any of our
services (the "Services", which include the Website), we appreciate that you are trusting us with your
personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to
you in the clearest way possible what information we collect, how we use it and what rights you have in
relation to it. We hope you take some time to read through it carefully, as it is important. If there are
any terms in this privacy notice that you do not agree with, please discontinue use of our Services
immediately.
This privacy notice applies to all information collected through our Services (which, as described
above, includes our Website), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the
information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in
obtaining information about us or our products and Services, when you participate in activities on the
Website or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the
Website, the choices you make and the products and features you use. The personal information we collect
may include the following:
Personal Information Provided by You. We collect names; email addresses; phone numbers; job titles;
usernames; contact preferences; and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must
notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This
information does not reveal your specific identity (like your name or contact information) but may include
device and usage information, such as your IP address, browser and device characteristics, operating
system, language preferences, referring URLs, device name, country, location, information about how and
when you use our Website and other technical information. This information is primarily needed to maintain
the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance
information our servers automatically collect when you access or use our Website and which we record in
log files. Depending on how you interact with us, this log data may include your IP address, device
information, browser type and settings and information about your activity in the Website (such as the
date/time stamps associated with your usage, pages and files viewed, searches and other actions you take
such as which features you use), device event information (such as system activity, error reports
(sometimes called 'crash dumps') and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet or other
device you use to access the Website. Depending on the device used, this device data may include
information such as your IP address (or proxy server), device and application identification numbers,
location, browser type, hardware model Internet service provider and/or mobile carrier, operating system
and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be
either precise or imprecise. How much information we collect depends on the type and settings of the
device you use to access the Website. For example, we may use GPS and other technologies to collect
geolocation data that tells us your current location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing access to the information or by disabling your
Location setting on your device. Note however, if you choose to opt out, you may not be able to use
certain aspects of the Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, and other outside
sources.
In order to enhance our ability to provide relevant marketing, offers and services to you and update
our records, we may obtain information about you from other sources, such as public databases, joint
marketing partners, affiliate programs, data providers, as well as from other third parties. This
information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user
behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom
profiles, for purposes of targeted advertising and event promotion.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the
fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described
below. We process your personal information for these purposes in reliance on our legitimate business
interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance
with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your account with us to a
third-party account (such as your Google or Facebook account), we use the information you allowed us to
collect from those third parties to facilitate account creation and logon process for the performance of
the contract.
To post testimonials. We post testimonials on our Website that may contain personal information. Prior
to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial.
If you wish to update, or delete your testimonial, please contact us at
[email protected] and be sure to
include your name, testimonial location, and contact information.
Request feedback. We may use your information to request feedback and to contact you about your use of
our Website.
To enable user-to-user communications. We may use your information in order to enable user-to-user
communications with each user's consent.
To manage user accounts. We may use your information for the purposes of managing our account and
keeping it in working order.
To send administrative information to you. We may use your personal information to send you product,
service and new feature information and/or information about changes to our terms, conditions, and
policies.
To protect our Services. We may use your information as part of our efforts to keep our Website safe
and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for business purposes, to comply with legal and
regulatory requirements or in connection with our contract.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may
need to inspect the data we hold to determine how to respond.
Fulfill and manage your orders. We may use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the Website.
Administer prize draws and competitions. We may use your information to administer prize draws and
competitions when you elect to participate in our competitions.
To deliver and facilitate delivery of services to the user. We may use your information to provide you
with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your
inquiries and solve any potential issues you might have with the use of our Services.
To send you marketing and promotional communications. We and/or our third-party marketing partners may
use the personal information you send to us for our marketing purposes, if this is in accordance with your
marketing preferences. For example, when expressing an interest in obtaining information about us or our
Website, subscribing to marketing or otherwise contacting us, we will collect personal information from
you. You can opt-out of our marketing emails at any time
Deliver targeted advertising to you. We may use your information to develop and display personalized
content and advertising (and work with third parties who do so) tailored to your interests and/or location
and to measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with
services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal
information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our
legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your
personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to
comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process,
such as in response to a court order or a subpoena (including in response to public authorities to meet
national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate,
prevent, or take action regarding potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the
following situations:
Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our
business to another company.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party
vendors, service providers, contractors or agents who perform services for us or on our behalf and require
access to such information to do that work. Examples include: payment processing, data analysis, email
delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to
use tracking technology on the Website, which will enable them to collect data on our behalf about how you
interact with our Website over time. This information may be used to, among other things, analyze and
track data, determine the popularity of certain content, pages or features, and better understand online
activity. Unless described in this notice, we do not share, sell, rent or trade any of your information
with third parties for their promotional purposes. We have contracts in place with our data processors,
which are designed to help safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They will also not share your
personal information with any organization apart from us. They also commit to protect the data they hold
on our behalf and to retain it for the period we instruct.
Affiliates. We may share your information with our affiliates, in which case we will require those
affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint
venture partners or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain
products, services or promotions.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following categories of third parties.
We only share and disclose your information with the following categories of third parties. If we have
processed your data based on your consent and you wish to revoke your consent, please contact us using the
contact details provided in the section below titled "
Data Analytics Services
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or permitted by law (such as tax,
accounting or other legal requirements). No purpose in this notice will require us keeping your personal
information for longer than 2 years.
When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize such information, 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.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical
security measures.
We have implemented appropriate technical and organizational security measures designed to protect the
security of any personal information we process. However, despite our safeguards and efforts to secure
your information, no electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal,
or modify your information. Although we will do our best to protect your personal information,
transmission of personal information to and from our Website is at your own risk. You should only access
the Website within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the
Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and
consent to such minor dependent's use of the Website. If we learn that personal information from users
less than 18 years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have collected from
children under age 18, please contact us at
[email protected].
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have
rights that allow you greater access to and control over your personal information. You may review,
change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws.
These may include the right (i) to request access and obtain a copy of your personal information, (ii) to
request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv)
if applicable, to data portability. In certain circumstances, you may also have the right to object to the
processing of your personal information. To make such a request, please use the contact details provided
below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw
your consent at any time. Please note however that this will not affect the lawfulness of the processing
before its withdrawal, nor will it affect the processing of your personal information conducted in
reliance on lawful processing grounds other than consent.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory authority. You
can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain features or services of our Website. To
opt-out of interest-based advertising by advertisers on our Website visit
http://www.aboutads.info/choices/.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access
to your personal information.
If you are under 18 years of age, reside in California, and have a registered account with the
Website, you have the right to request removal of unwanted data that you publicly post on the Website. To
request removal of such data, please contact us using the contact information provided below, and include
the email address associated with your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the Website, but please be aware that the data may not be
completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
(1) every individual who is in the State of California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol address, email address and account name
NO
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history and financial information
YES
C. Protected classification characteristics under California or federal law
Gender and date of birth
NO
D. Commercial information
Transaction information, purchase history, financial details and payment information
NO
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other
websites, applications, systems and advertisements
NO
G. Geolocation data
Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
NO
I. Professional or employment-related information
Business contact details in order to provide you our services at a business level, job title as well
as work history and professional qualifications if you apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or
summary about, for example, an individual's preferences and characteristics
NO
We may also collect other personal information outside of these categories instances where you
interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
WebSafety Ninja collects and shares your personal information through:
Targeting cookies/Marketing cookies
Social media cookies
Beacons/Pixels/Tags
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at
[email protected], or by referring to the contact details at the
bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit entity that processes the
information on our behalf.
WebSafety Ninja has disclosed the following categories of personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months:
Category B. Personal information, as defined in the California Customer Records law, such as your
name, contact information, education, employment, employment history and financial information.
WHO WILL YOUR INFORMATION BE SHARED WITH?.
WebSafety Ninja has not sold any personal information to third parties for a business or commercial
purpose in the preceding twelve (12) months. WebSafety Ninja will not sell personal information in the
future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information, subject to certain
exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her
right to free speech, our compliance requirements resulting from a legal obligation or any processing that
may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business
purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that
is de-identified in response to a consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person
about whom we have the information in our system. These verification efforts require us to ask you to
provide information so that we can match it with information you have previously provided us. For
instance, depending on the type of request you submit, we may ask you to provide certain information so
that we can match the information you provide with the information we already have on file, or we may
contact you through a communication method (e.g. phone or email) that you have previously provided to us.
We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to
make the request. To the extent possible, we will avoid requesting additional information from you for the
purposes of verification. If, however, we cannot verify your identity from the information already
maintained by us, we may request that you provide additional information for the purposes of verifying
your identity, and for security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to
restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a
request from an authorized agent that does not submit proof that they have been validly authorized to act
on your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon
receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later
than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at
[email protected], or by referring to the
contact details at the bottom of this document. If you have a complaint about how we handle your data, we
would like to hear from you.
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
[email protected] or by
post to:
WebSafety Ninja
2 Offenbeker Bemden
Reuver, Limburg 5953 MX
Netherlands
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it in some circumstances. To request
to review, update, or delete your personal information, please