Last updated June 25th, 2020.
C/O Westmusa, Inc
235 West 48th St, Suite 42B
New York, NY 10036, USA
(Hereafter “Miradore” or “We”)
2. Contact person
Attn: Privacy Officer
C/O Westmusa, Inc
235 West 48th St, Suite 42B
New York, NY 10036, USA
3. Name of Register
Customer and Marketing Register.
4. Legal Bases for Processing and How We Use the Information We Collect
Our legal bases for processing personal data are our legitimate interest, the performance of a contract and in certain cases your consent.
We process your personal data for the following purposes:
- Delivery of products and services
We use your personal data to operate, maintain, enhance and provide all features of the Service; to provide the services and information that you request; to respond to comments and questions; and to provide support to users of the Service.
- Customer relationship management
We may use your email address or other information to contact you for administrative purposes, such as customer service and to address intellectual property infringement, right of privacy violations or defamation issues related to the personal data posted on the Service.
- Development of products and services
We use your personal data to understand and analyze the usage trends and preferences of our customers and website visitors; to improve the Service; and to develop new products, services, features, and functionality. We may contact you to complete surveys that we use for quality assurance purposes.
- Marketing purposes
We may use your contact details in order to provide you with updates on promotions and events, relating to products and services offered by us and by third parties with whom we work. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
We use automated decision-making (incl. profiling) to identify personal profiles, online behavior, age and consumer habits. We use this information to target advertising in our and others’ online services and to develop our services.
5. What Information Do We Process and Where Do We Receive it From?
a) Information Provided by You
When you sign up for and use the Service, consult with our customer support team, send us an email, post on our community, or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include your name, email address, phone number, and credit card or other billing information.
b) Information Collected Automatically
Information Collected from your use of the Service
We may receive information about how and when you use the Service, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Service for both you and for all of our users.
Cookies and tracking
We may use Google Analytics or other website analytics providers to measure and evaluate access to and traffic on our website and create user navigation reports for our Site administrators.
6. How We Disclose Information
We are committed to your privacy and we do not sell any personal data.
We may disclose your information, including personal data, as described to you at the time of collection or disclosure or as follows:
a) Subcontractors. We may disclose your information, including Personal Data, to our vendors, service providers, agents, or others who perform functions on our behalf as subcontractors. For example, we may disclose your information to third-party service providers to process payments on our behalf.
b) Business Transfers. We may disclose your information, including Personal Data, to another entity in connection to negotiations of an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
d) Legal Compliance. We may disclose your information, including Personal Data, to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding. We may also disclose your information and Personal Data in response to a subpoena, warrant, court order, or other legal process or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
e) Aggregate or Anonymous Information. We may disclose aggregate, anonymous information about you for marketing, advertising, research, compliance, or other purposes.
7. Transfers outside the EU/EEA
Our servers are located in the European Union. All Customer Data (including Personal data) stored by Miradore is stored and processed in the EU. In some cases our subcontractors may need to process some of your personal data (e.g. contact details in customer relationship management applications or customer support information in ticketing systems) in other locations than the EU. These cases are considered as data transfers outside the EU/EEA. Therefore we have made sure that the subcontractor complies with regulations and are committed to using the EU Commission’s standard contractual clauses and in some cases when applicable they are covered by the Privacy Shield system.
8. Data Retention
We only retain the Personal Data collected from a User for as long as the User’s account is active or otherwise for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.
We take reasonable measures that ensure no incompatible, outdated or inaccurate personal data is stored in the register taking into account the purpose of the processing. We correct or erase such data without delay.
9. Data Security
Miradore follows generally accepted industry standards to protect the information and personal submitted to us, both during the transmission and once we receive it. Miradore ensures that its employees and other persons authorized to process the personal data have committed to confidentiality. We maintain appropriate administrative, technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use TLS technology to encrypt data during transmission through the public Internet, and we also employ application-layer security features to further anonymize personal data.
If you believe your personal data has been compromised, please contact us as set forth in the “How to Contact Us” section.
10. Your Rights as a Data Subject
a) Data Requests, Correction and Removal. As a data subject you have the right to receive a copy, access or correct any Personal Data we hold about you, or to request that we delete any information about you, by contacting us as set forth in the “How to Contact Us” section.
b) Right to Object and Complain. As a data subject, you have a right, according to the EU’s General Data Protection Regulation, to object to or request the restriction of the processing and lodge a complaint with a supervisory authority responsible for processing personal data. On grounds relating to your particular situation you also have the right to object other processing activities when the legal basis of processing is our legitimate interest. In connection with your request, you shall identify the specific situation, based on which you object to the processing. We can refuse the request of objection only on legal grounds.
c) Right to withdraw consent. Insofar as the processing is based on consent, you also have the right to withdraw or change your consent. Withdrawing your consent does not affect the lawfulness of processing before the withdrawal of the consent.
d) Opting out from Commercial Communications. If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section.
11. Third Party Services
The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.