Effective Date 25 May 2018
Who are we?
Connexity, Inc. is a company incorporated in the State of Delaware, USA and has its principal office at 2120 Colorado Ave., Suite 400, Santa Monica, CA 90404.
Certain of the Services may be provided by our subsidiary Connexity Europe GmbH, with whom we may also share your information. Connexity Europe GmbH is a company registered in Germany in accordance with the laws of the District Court of Mannheim under company register number HRB 705360 and with its registered office at Ruschgraben 133, 76139 Karlsruhe, Germany. “Connexity” or “Shopzilla” and the terms “we”, “us” and “our” refer to Connexity, Inc., except where a Service is provided by Connexity Europe GmbH, in which case the terms “we”, “us” and “our” refers to Connexity Europe GmbH.
Our data protection representative can be contacted directly here: email@example.com
Summary of key principles
We collect and process information about you when you provide it to us, when you use our Sites or when we are provided it by certain third parties. This information may be transmitted to, held and processed by us in the United States of America. We pseudonymize the data that we directly collect that may be considered personal prior to storing it.
We typically use this information for fraud prevention purposes and to improve our Sites and Services;
We may disclose this information to authorized third parties including our merchants, affiliates and third-party service providers for these purposes;
You may object and/or withdraw consent to us processing your information in certain circumstances and at any time opt-out of certain activities as set out below (see section VII);
If you have any questions or concerns about privacy at Connexity, please contact us by e-mail at firstname.lastname@example.org;
Our websites and our services are not designed or intended for use by children under 16; and
I. What information do we collect about you and where do we collect it from?
(a) Information you give us: We collect your information when you choose to contact us with an enquiry by mail or by e-mail at email@example.com.
(b) Information we collect about you: We automatically collect certain information from you when you access our Sites including your IP address and information relating to your browser, operating system, ISP, the third-party website from which your visit originated and how you use our Sites such as the web pages you visit, and the duration of your visits.
(c) Information we receive from other sources: Third party merchants who use our Sites to advertise their products provide us with information regarding any visits you make to their website via our Sites and any purchases made by you as a result. This information includes your IP address, referring URL, browser and/or device type and details about your order but no other personal data.
II. How we use & share the information collected
We use the information we collect about you for the following purposes:
- to verify sales made by third party merchants as a result of them using our Sites to promote their products and calculate our fees to them;
- for fraud prevention;
- to improve our Sites and Services and to carry out your requests and
respond to your enquiries;
- to allow third parties to provide adverts to you on our Sites that we
think may be of interest to you;
- to advertise products to you on third party sites based on your preferences and likely interests.
We process your information for the above purposes on the basis it is in our legitimate interests or consent where we ask it of you. You may object to processing by us for this reason at any time in accordance with section VII below.
We may disclose your information to:
- Our third-party service providers who perform functions on our behalf in
connection with the operation of the Sites or Services e.g., providers who
host and manage data, etc.;
- Our third-party advertising partners to personalize content and adverts
that appear on our Sites and to advertise products to you on third party
sites which are tailored to meet your preferences and likely interests;
- Our third-party analytics partners to analyze Site traffic and understand
customer needs and trends. We may use your anonymized information by itself
or aggregate it with information we have obtained from others to produce
research reports and other information and data about online shopping for
participating merchants and other customers, as well as media and other
- Our parent company, subsidiaries or other affiliated companies
(“affiliated companies”) for operational, marketing and promotional
- A third-party purchaser of all or any of our assets, where such
information is one of the assets transferred;
- A prospective seller or buyer of our business or assets; and
- A third-party if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfil a government request, including for national security or law enforcement reasons; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Sites, or other users; or (d) in an emergency to protect the health and safety of our Sites’ users or the general public.
III. Transferring your information outside the European Economic Area
Some of the information we collect about you is transferred to and stored on our servers in the United States of America. When personal data is transferred from within the EEA to any of our affiliates outside the EEA we use the EU model clauses to ensure that the transfer is subject to adequate safeguards in accordance with our legal obligations.
IV. How long we store your information
The information we collect about you when you access our Sites (including referring URL, page visits, browser and/or device type, time and date) and the information provided by our third-party merchants is pseudonymized immediately prior to storing it, and we delete data we store after 10 years.
We store the information you provide to us when you contact us by email for a period of up to 5 years.
V. Cookies and similar technologies
We automatically receive and store certain types of information whenever you use our Sites by using "cookies" and analogous technology. "Cookies" are small files that we place on your computer or your Web browser memory to enable our systems to recognise your browser.
A couple of important notes about this opt-out guide: (1) it includes all the advertising networks that Connexity works with, but also many that Connexity does not work with; and (2) it relies on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – for a general explanation of how Opt-out Cookies work, please click here. Therefore, if you buy a new computer, change web browsers or delete these Opt-out Cookies from your computer, you will need to perform the opt-out task again.
You may be able to direct your internet browser not to allow cookies and you can delete existing cookies from your computer. Please note, however, some elements of our Sites will not function properly or be available to you.
VI. Security of information
We use a secure server hosting location in the U, firewall protection, controlled access and encryption technology to protect your data. Please be advised, however, that while we strive to protect your information, we cannot guarantee or warrant the security of any information you disclose or transmit to us over the internet.
VII. Your rights
(a) Right to object to processing based on our legitimate interests: You have the right to object to us processing your personal data on the grounds of it being in our legitimate interests.
(b) Right to access, delete and correct your personal data: You have the right to request a copy of the personal data we hold about you.
(c) Right to be forgotten: In certain circumstances you can ask for the personal data we hold about you to be erased from our records.
(d) Right to restriction of processing: Where certain conditions apply, you may have a right to restrict the processing of your personal data.
(e) Right to object to profiling: You may object to us undertaking any profiling of you in relation to serving you with advertisements which we think may be of interest to you by clicking here. You can also prevent any profiling by setting your internet browser not to allow cookies and by using the opt-out tool mentioned in section V above.
VIII. Privacy Shield
Connexity (and its wholly-owned subsidiary, Connexity Audience, Inc.) participates in the EU-U.S. Privacy Shield framework. Connexity is committed to subjecting all personal data received from EU member countries, in reliance on the Privacy Shield, to the principles underlying the Privacy Shield (the “Principles”). To learn more about the EU-U.S. Privacy Shield program, and to view Connexity’s certification, please visit the U.S. Department of Commerce site at https://www.privacyshield.gov/.
IX. Accountability for Onward Transfer
If we transfer personal data received from EU member countries, in reliance on the Privacy Shield, to a third party acting as a controller, we will do so consistent with any notice provided to data subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the personal data for limited and specific purposes consistent with any consent provided by the data subjects; (ii) provide at least the same level of privacy protection as is required by the Principles and notify us if it makes a determination it cannot do so; and (iii) cease processing of the personal data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Connexity has knowledge that a third party acting as a controller is processing such personal data in a way that is contrary to the Principles, Connexity will take reasonable steps to prevent or stop such processing.
With respect to our third-party agents, we will transfer only the personal data needed for an agent to deliver to Connexity the requested product or service. Furthermore, we will (i) permit the agent to process such personal data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal data transferred in a manner consistent with Connexity’s obligations under the Principles; and (iv) require the agent to notify Connexity if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
Connexity remains liable under the Principles if an agent processes personal data received from EU member countries, in reliance on the Privacy Shield, in a manner inconsistent with the Principles, except where Connexity is not responsible for the event giving rise to the damage.
In the event that you wish to make a complaint about how your personal data is being processed by us or that we have not taken any action requested by you in relation to your rights set out above, you have the right to lodge a complaint directly with the applicable supervisory authority and our data protection representative.
The details for each of these contacts are:
EU individuals may direct any inquiries or complaints regarding our Privacy Shield compliance to Connexity’s Data Protection Representative contact above. Connexity will respond within 45 days. If you have an unresolved concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge), the International Centre for Dispute Resolution/American Arbitration Association, at http://go.adr.org/privacyshield.html. Finally, as a last resort and in limited situations, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel.
Connexity’s commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
As our Sites nor our Services are not intended for use by children under 16. Also, if you are under 18, you should use our Sites and Services and submit information only with involvement of a parent or guardian.
X. Online merchants and third-party policies
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