- Personal Information Privado Collects
- How Privado Uses and Stores Your Personal Information
- How Privado Protects Your Personal Information
- Sharing Personal Information with Third Parties
- Personal Information From and Outside of the European Union
- Your Rights
- Cookies and Other Technologies
- Notice to Californian Residents – Your California Privacy Rights
- Do Not Track
- Contact Privado
- Personal Information Privado Collects.
When you use, access or interact with the Service, we collect:
- IP address;
- User agent;
- Search terms.
- How Privado Uses and Stores Your Personal Information, and our legal basis to process Your Personal Information (GDPR only).
This is how we use this information:
- Provide our Service
We provide you with search services and functionality including search results of our web search partner, in response to your online search queries. For this purpose, Privado processes your information on the basis of (i) a legitimate interest (i.e. to process the search and provide search results) and/or (ii) the right to disseminate information and the freedom of expression, including the right to receive and impart information and ideas. We delete all PII once our fraud detection process, which takes 96 hours, has been completed (as further specified in the paragraph below).
- Detect and prevent fraud on our Service.
Privado requires your PII to conduct fraud detection on potentially fraudulent and illegal uses of the Service. We need this information for 96 hours to conduct this fraud analysis. Following this period, we will delete all PII. For this purpose, Privado processes this information on the basis of a legitimate interest for preventing fraud.
- Customer Support.
We also use support related information you provide to us to provide you with support and handle your complaints and feedback. This information is not collected through the Service, it is information you voluntarily provide us when you contact Privado via email or otherwise (such as name, email address and any other PII you provide). For this purpose, Privado processes this information on the basis of a legitimate interest (e.g. to process your email, handle your request, etc.). We will retain this information for the time it takes to provide you with the support you requested and to handle your complaints. We may keep your information for longer periods in case of disputes and other legitimate reasons described in the next section“Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request”.
- Disputes and Enforcement; Applicable law, regulations or Enforceable Governmental Request.
We use your PII and support related information to take action in case of a dispute involving you in connection with the Service and to enforce the terms and conditions applicable to the Service. We also use your PII to comply with legal and regulatory requirements (e.g., the disclosure of information to law enforcement or tax authorities), and to protect against suspicious or other illegal activities. We will retain this PII for the amount of time as required by law to fulfill the above purposes. This may include ensuring that we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your PII or dealings.
How Privado Protects Your Personal Information
We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. As the security of information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
Sharing Personal Information with Third Parties.
During the limited 96 hours period in which we process your PII:
- We host your Personal Information on Amazon Web Services in servers located in North Virginia (USA), North California (USA) and Frankfurt (Germany).
- We grant access to our subsidiaries, affiliates, parent companies and our and their staff on a strict “need to access” basis. Such intercompany transfers are covered by an agreement entered into by members of our group (an internal processing agreement) which contractually obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to.
- If we are required by law, regulation or competent authority, we may share your PII with law enforcement or other competent authorities and any third party as may be required (e.g. to respond to claims or satisfy any legal process, subpoena, or governmental request; or to protect the rights, property, or personal safety of Privado’s users, its partners, or the general public). We will also share this information with our professional advisors in the scope of this purpose.
- In the event we go through a business transition such as a merger or acquisition by another company, consolidation, change of control, reorganization, or sale of all or a portion of its assets, your information will be among the assets transferred. With respect to sharing of your PII, we take appropriate measures to minimize the PII that we disclose to the above third parties, and we require these third parties to keep the data secured. In any case other than the above, we will not share your PII with third parties without your prior consent.
Transferring Personal Information From and Outside of the European Union
We will take appropriate steps to ensure that transfers of your PII are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end, if we as the data controller share your information with our corporate affiliates or third party service providers outside the EEA, we have – prior to sharing your information with such corporate affiliate or third party service provider – established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission) or EU – US Privacy Shield certification. We will provide further information on the means to ensure an adequate level of data protection on request.
The following rights (which may be subject to certain exemptions or derogations), shall apply to the users of the Service (some of which only apply in certain jurisdictions and/or certain individuals in certain circumstances):
- You have a right to access PII held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
- You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
- If you no longer want us to use your Personal Information, you can request that we erase your Personal Information.
- You have a right to restrict the processing of your Personal Information, for example in case when we no longer need your Personal Information for the initial purposes for which they were collected, but they may be required for the establishment, exercise or defense of legal claims.
- You have a right to obtain a portable copy of PII which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of PII transferred to another data controller in a structured, commonly used and machine-readable format.
- You also have a right to request details of the basis on which your PII is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
- You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your PII. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the PII requested to you or processing your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us – please see the “Contact Privado” section below. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. In the event that your request, for example, would impact the rights of others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
Cookies and Other Technologies.
Do Not Track.
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature“); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Privado does not currently respond or recognize DNT Feature signals.