Last Updated: March 30, 2020
- GFCO mobile applications (each an “App”),
- the features and services available through our Sites and Apps
- The Information We Collect
- Use and Processing of Information
- Disclosure of Your Information
- Online Advertising
- How We Protect Your Information
- Retention of Your Information
- International Users
- Third Party Links and Services
- Your Choices
- Access and Data Subject Rights
- Your California Privacy Rights
- Contact Information
THE INFORMATION WE COLLECT
We collect information related to our Services and Interactions directly from users, automatically related to their use of the Services and our Interactions, as well as from third parties. We may combine the information we collect from these various sources.
Information You Provide to Us. We collect information directly from users:
- Account registration, management, profile creation and modification
- Account access and use, as well as uploading content to the Services and other associated activities
- Access to and use of the Sites and Apps
- Submission of payment information
- Event registration and attendance
- Participation in surveys, contests, sweepstakes and promotions sponsored by GFCO
- Signing up to receive alerts or other information via email, text or instant messages from GFCO
- Customer service, technical support, and related communications
- Participation in communities, commenting on blog entries, interacting with use on social media, and participation in other forums
- Submission of an application or resume to work at GFCO
The types of information we collect directly from you are: your name, e-mail address, phone number, postal address, other contact information, credit card and billing details, including billing address, communications preferences, payment and transaction history, and any other information you submit to the Services or otherwise provide to us. We also collect certain demographic data if you provide it to us including age, gender, preferred language, and current location.
Automatically Collected Information. We also collect information through automated and technical means as you browse our Sites, use our Apps, or otherwise use the Services:
- Analytics: We compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences and other information.
Information We Collect From Third Party Sources. In some cases, we collect user information from third parties.
- Third Party Platforms and Social Media Sites. When you interact with us or post content about us on third-party social media platforms – like Facebook, Twitter, Tumblr, LinkedIn, YouTube or Pinterest – we may collect certain information about that interaction; the information that we may collect is based on your settings on and the policies of these social media platforms. We may also allow you to post certain information from these platforms to your GFCO profile, and permit you to login to the Services using your third-party social media account, in which case you will be asked to consent to our access and collection of certain information from your social media profile, subject to the policies of that platform.
- Other Third-Party Sources. We also may collect information about you that we may receive from business partners, marketers, analysts and other sources to, enable us to verify and update information contained in our records and better customize the Services for you. We may also collect information from credit reporting agencies to determine your creditworthiness, credit score and credit usage, in compliance with and to the extent permitted by applicable laws.
- Referrals. We may from time to time conduct a referral service so that you may introduce people you know to our Services, in accordance with applicable local laws. If you choose to use our referral service to tell someone about our Services, we will provide you with a template message and referral code to send to your friend. We will not collect the referral’s information unless he/she signs up to use the Services with the referral code.
USE AND PROCESSING OF INFORMATION
We generally use the information we collect from and about you to provide and operate the Services, respond to user requests, for customer service and support, to protect our rights and those of others, to send marketing communications, to help us personalize user experiences and to improve the Services, as explained in more detail below.
Legal Bases for Processing Under EU Law. Where EU data protection law applies, we process your personal data as defined by applicable EU law for the purposes set out in the table below, under the following legal bases:
- Our Contract With You. Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us and provide the Services to you).
- Our Legitimate Interests. Our processing is necessary for our legitimate interests, including to protect the security our Services; to protect the health and safety of others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of users; to personalize user experiences and content; to understand and analyze usage trends; and to improve the Services.
- Legal Compliance. Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes).
- Your Consent. When we have your consent as defined by applicable law.
- In addition, we may process information to the extent necessary to protect the health, safety or vital interests of any person and to establish, protect and defend our legal rights.
- Purpose of Use and Processing. Generally, we use the information we collect as set forth in the below table:
Purposes of Use and Processing of Information
EU Legal Bases
Providing Support and Services
Our Contract with You
Our Contract with You
Improve Services and Analytics
Our Legitimate Interests
Communicate with You
Our Contract with You
Personalize Services and Ads
Our Legitimate Interests
Marketing and Promotions
Our Legitimate Interests
Protect Legal Rights and Prevent Misuse
Our Legitimate Interests
Complying with Legal Obligations
General Business Operations
Our Legitimate Interests
DISCLOSURE OF YOUR INFORMATION
We disclose the information we collect, in the following ways:
- Business Partners and Third Parties. We may share your information with business partners who jointly sponsor events with us, from time to time; where required by applicable law, we will obtain your prior consent. You may at any time withdraw your consent or tell us to stop sharing your personal information (as defined under applicable law) with business partners and third parties by following the opt-out process described in the “Your Choices” section below.
- Third-Party Service Providers. We use a variety of third party service providers that perform functions on our behalf, such as hosting, billing and payment processing, push notifications, storage, bandwidth, content management tools, analytics, customer service, fraud protection, etc.
- General Business Operations. Where necessary to the administration of our general business, accounting, record keeping and legal functions, to our tax advisors, legal counsel and other professional services entities or agents.
- Legal Compliance and Protection of Rights. We may also use or disclose information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Services; (b) establish, protect and defend our rights or property, the Services or our users, including to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our User Agreement, other agreements or policies, or as evidence in litigation in which we are involved; and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or users of the Services or the public. This includes exchanging information with other companies and organizations for fraud protection.
- Other Users. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential and may be accessed by others. For example, if you submit a product review on one of our Sites, we may display your review (along with the name provided, if any) on other GFCO Sites and on third-party websites. Moreover, if you provide a comment on our blog, other blog readers will be able to review your comments, and if you interact with us on our social media pages, your comments will be publicly available. So, please take care when using these features. If you’d like to request removal of information that we have posted about you, please contact us as set forth in the “ Your Choices” section below.
- Aggregate/Anonymous Information. We may share aggregate/anonymous information about use of the Services with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
- Business Transfers. As we continue to develop our business, we may seek to buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
To request more information about the companies to whom we have disclosed your information, please contact us as set out in the “Contact Information” section.
Like most Sites and Apps and online Services, we use “cookies,” web beacons (a/k/a pixel tags), analytics devices and similar technologies (some of which are operated by third parties) to record your preferences, gather information about the use of our Services, personalize content and ads and track information about the performance of our advertisements. We may also use these technologies to monitor traffic and make the Services easier and/or more relevant for your use. We may combine this information with other information we collect from you.
Cookies. These are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes and associate with small text files that we use to record certain information regarding your use of our online Services, your preferences and actions, and other device and usage data as described above. Some cookies allow us to make it easier for you to navigate our Sites, Apps, and Services, while others are used to enable a faster log-in process, personalize your use of the Services, or otherwise allow us to track your activities while using our Services. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline or block cookies if you prefer. If you delete your cookies or if you set your browser or device to decline or block these technologies, some features of the Services may not work or may not work as designed.
Pixel tags (a/k/a web beacons or clear GIFs). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages or within emails. We or our service providers may use pixel tags in connection with our Services to, among other things, track the activities of users of the Site and App, help manage content, measure ad performance and compile statistics about usage. We or our service providers also use pixel tags in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
More Information. For more information and to exercise your choices regarding Facebook and Google ads:
You can also learn more about online advertising at www.aboutads.info/consumers and opt out of interest-based advertising from many participating ad companies at the ad industry websites below:
Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:
- Apple: http://support.apple.com/kb/HT4228
- Android: http://www.google.com/policies/technologies/ads/
- Windows: http://choice.microsoft.com/en-US/opt-out
Please note that opting-out of advertising network services does not mean that you will not receive advertising while using our Services or other services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs.
HOW WE PROTECT YOUR INFORMATION
We take technical, physical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. We encourage you to take steps to protect your information and prevent unauthorized access to your password or account by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.
RETENTION OF YOUR INFORMATION
We retain your information a for as long as required to satisfy the purpose for which it is collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary for our legal obligations or to establish, protect, or defend legal claims.
GFCO is a global company with affiliates, service providers and partners in multiple jurisdictions. As such, your information may be transferred, accessed, stored and otherwise processed by us and these third parties for the purposes described above, and subject to requests from law enforcement, in jurisdictions outside of your home jurisdiction, including Canada, the United States, Mexico and the European Economic Area and other jurisdictions in which we or our service providers operate. Some of these jurisdictions, including Canada and the United States, may not provide an equivalent level of data protection as your home jurisdiction. By providing us with your information, you acknowledge any such transfer, storage, or use. We will take steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
Individuals in the EEA. If you are located in the European Economic Area, where your information is processed by members of our group or third-party service providers and processors in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will take appropriate measures to ensure your information is subject to adequate safeguards, such as by signing relevant EU standard contractual clauses approved by the European Commission (the form for these clauses can be found here) or another measure that has been approved by the European Commission as adducing adequate safeguards for the protection of information when transferred to a third country. If you are in the EEA, you have the right to obtain details about the mechanism under which your information is transferred to a third country. For more information about these transfer mechanisms, please contact us as set out in the “Contact Information” section below.
THIRD PARTY LINKS AND SERVICES
If you would like to update your preferences on the types of communications you receive from us, or opt out of marketing communications from us, you may do so at any time by updating the communication preferences in your account profile. Please note that we may continue to send non-promotional communications such as important notices, payment confirmations and transaction-related emails and other information about your use of the Services. If you would like to opt-out of (i) marketing communications, or (ii) being included in any Custom Audience campaigns (see the “Online Advertising” section above for more information), you may also do so by emailing us your request at info@GFCOltd.com.
ACCESS AND DATA SUBJECT RIGHTS
Subject to applicable law and as explained in this section, you may have certain rights with respect to the information we collect and process about you.
Complaints. If applicable, you may make a complaint to the privacy regulator or supervisory authority in the country where you are based. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.
EU Data Subject Rights. Subject to applicable laws, you may have the following rights:
- To obtain access to and/or a copy of certain information we hold about you
- To obtain, in certain circumstances, a copy of certain information we of yours in a structured, commonly used and machine readable format, and to ask us to transfer this to a third party of your choice
- To request that we update your information we hold that is out of date or incorrect
- To request that we delete certain information we hold about you
- To request that we restrict the way we process and disclose certain of your information
- To revoke your consent for the processing of your information, to the extent our processing of your information is not based on another legal basis
- To object to certain processing of your information as follows:
- right to object to direct marketing: you may object to our processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling). See “Your Choices” above for more info.
- right to object to processing (including profiling) based on legitimate interest grounds: in addition where we are relying upon our legitimate interests to process information, you may object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the information for the establishment, exercise or defense of legal claims. We will consider each case on an individual basis.
You may exercise your rights or make a request regarding your information held by us, request further information about your legal rights under applicable law, or submit a complaint about our privacy practices by contacting us at any time, using the contact details set forth in the “Contact Information” section below.
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information to provide services to you or to comply with a legal obligation. Moreover, you will not be permitted to examine the information of any other person or entity. We also may request you provide us with information necessary to confirm your identity before responding to your request.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers of GFCO who are California residents to request certain information, once per year, regarding our disclosure of their personal information (as defined by California law) to third parties for their own direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. To opt out of future sharing for these purposes, please send an e-mail to info@GFCOltd.com.
This Cookie Notice explains:
- What are Cookies?
- Types of Information Collected and Reasons for Collection
- Types of Cookies We Use
- Duration of Storage of Cookies on Your Device
- Cookie Management
- Consequences of Deactivation of all Cookies
- Changes to the Cookies Notice
- Contact Us
What are Cookies?
Cookies are small text files that are placed on your computer or mobile device that enable us to, among other things,: (i) recognize your computer or device; (ii) store your preferences and settings; (iii) understand the parts of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. For more information on cookies, go to www.allaboutcookies.org.
The term “Cookie” is used in this Cookie Notice in the broad sense to include all similar techniques and technology, including web beacons, tracking pixels, and log files.
Types of information collected and reasons for collection
- To remind us who you are and to find your account information in our database when you access the Services so you do not need to log in at every visit. This helps us to provide you with service tailored to your specific needs and interests. A cookie is created when you register for the Services
- To determine the browser the visitor uses so the Services can be designed to work properly with the most common versions of different browsers
- In conjunction with sending you e-mail newsletters
- To analyse your use of our Services and to generate analytics regarding our Services
- To estimate our audience size. Your browser is given a unique cookie that helps us determine whether yours is a repeat visit or a first visit
- To determine whether you are visiting our Services for the first time
- To save viewing preferences (e.g. layout, sizing preferences, language etc.);
- Facilitate your purchases and your orders
In addition, Cookies allow us to do the following:
- Customise your visit: We may use information collected during your visit to facilitate your next visit to our Services;
- Customise the advertising and marketing messages that appear on the Services, whether ours or those of third parties; and
- Analyse customer trends: We compile information on individual Services visits and analyse them as a whole in aggregated form.
Type of Cookies We Use
We use first party and third party Cookies for several reasons. Some Cookies are required for technical reasons in order for our Services to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies enable us to track and target the interests of our users and to enhance the experience on our Services. Third parties also serve Cookies through our Services for advertising, analytics and other purposes. The specific types of first and third party Cookies served through our Services and the purposes they perform are described in more detail below.
– First-party Cookies
These cookies are created by GFCO. They are, for the most part, used to allow you to browse our Services and use its features. First-party cookies include:
- Essential Website Cookies: These Cookies are strictly necessary to provide you with services available through our Services and to use some of its features, such as access to secure areas.
- Functional Cookies: These Cookies allow you to browse our Services or benefit from some of its features, such as memorizing language preferences or placing orders online.
- Analytics Cookies: These Cookies allow us to collect statistics (aggregated and anonymous) on the usage of the Services by you and other visitors. This information helps us improve the features offered on the Services.
– Third-party cookies
In addition to our proprietary Cookies, some third-party and affiliated companies may place Cookies on your computer, access them and associate web beacons with them. These Cookies enable third-party features or functionalities to be provided on or through the Services. The parties that set these third-party Cookies can recognize your device both when it visits our Services and also when it visits certain other websites. Third-party cookies include:
- Functional Cookies: These Cookies are defined by third parties who support our Services and they allow you to use useful services and features, such as support services or payment processing.
- Online Behavioural Advertising Cookies: These Cookies are defined by our advertising partners and collect data about your browsing habits, as well as your preferences for products and services. This information allows GFCO and the ad networks that we work with to display relevant ads on the most relevant pages of partner sites and the GFCO Services. For example, third parties or affiliates may manage GFCO advertising programs on a non-GFCO site.
Duration of storage of cookies on your device
The duration of storage of Cookies on your device may vary, depending on the category to which they belong: temporary or permanent.
– Temporary Cookies
We use temporary Cookies on all of our secure pages to assign and register a session ID. This identifier is also used for internal reporting purposes. It does not allow us to identify you personally by name and this type of Cookie does not leave any information recoverable on your hard drive. Most of our proprietary Cookies fall into this category and expire when you close your Internet browser.
– Permanent Cookies
Our proprietary analysis Cookies and third-party Cookies are permanent Cookies. They allow us to understand visitors’ browsing behaviour over a longer period of time or to provide you with additional features related to your Services customisation requests and the content that you have saved or stored. They can stay on your computer for 24 hours, a week or several years, depending on their function. This means that these Cookies survive after your browser is closed and can be used by our Services to recognize your computer when you re-open your browser later.
If you do not want to receive some of the categories of Cookies used on our Services, you can use the means described below to disable them. Note, however, that we will still need to set a Cookie on your device to remember your preferences when you visit our Services again from a single browser.
At the moment, it is technically impossible for you to synchronise your settings between your browsers and your devices (your computer or your smartphone). You must set them on each browser/device that you currently use and each time you use a new browser or device.
You can decide whether to accept or reject Cookies. You can exercise your Cookie preferences by managing Cookies from your web browser. As the means by which to activate or deactivate Cookies varies from one web browser to another, you should visit your web browser’s help menu for more information on Cookie preferences. You can also configure your browser at any time to be notified of the receipt of a Cookie, so that you can decide whether you want to accept it or not. Cookies do not under any circumstances read the data from your hard drive and you can delete them from your computer at any time.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.
Consequences of Deactivation of all Cookies
If you choose to deactivate all Cookies, you may continue to use certain parts of our Services. However, some useful features may not work anymore.
Please note that if you have disabled one or more Cookies, we may continue to use the information that was collected by such Cookies before they were deactivated. However, we will cease to collect any additional information via the opted-out Cookie once a Cookie has been deactivated.
Changes to the Cookies Notice