Last updated June 9, 2021
If you are in Europe:
for the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), the data controller of information you submit, or we otherwise collect when you use our Application Site, is Cyber Scent Work, Inc., and we can be reached at the address under the section “How to Contact Us” below; and
“information” covers all personal data processed by us which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect via the Application Site depends on the content and materials you use, and includes:
You may also provide us with special categories of personal data under the GDPR (also known as sensitive data) about yourself and/or third parties, such as health information. When you provide such information, we will seek your explicit consent unless it is being published in relation to the various activities of the Application Site, such as creating an account, registering your dog, or submitting an entry.
If you provide “personal data” to the Application Site, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of CSW and the authorized third parties referred to herein located in the United States.
Information our servers automatically collect when you access the Application Site, such as your native actions that are integral to the Application Site, including logging in, registering a dog, and submitting an entry, as well as other interactions with the Application Site and/or other users, such as sending a message to Cyber Scent Work through the Application Site itself, via server log files. This information is collected passively using various technologies and may include the type of internet browser or mobile device you use, any website from which you have come to the Application Site, your operating system, and may also include location data through an IP address that identifies the city and state where you logged into the Application Site or your precise geo-location if you have permitted your device to provide that information to us. CSW may store such information itself or such information may be included in databases owned and maintained by CSW affiliates, agents, or service providers.
In an ongoing effort to better understand and serve the users of the Application Site, CSW often conducts research on its customer demographics, interests and behavior based on information we collect. We may de-identify and/or aggregate the information collected through the Application Site for research purposes or any other purposes, and we may share this data with our affiliates, agents, or business partners.
To access information on the Application Site and use our services, a user may be required to register with CSW. During registration, a user is required to give certain information (such as name and email address). This information is used to contact you about the services in which you have expressed interest and provide a way for a user to log in to utilize other protected areas of our services.
USE OF YOUR INFORMATION
Create and manage your account.
Email you regarding your account, registered dogs, orders, entries, or reviews.
Fulfill and manage purchases, orders, payments, and other transactions related to the Application Site.
Generate a personal profile about you to make future visits to the Application Site more personalized.
Increase the efficiency and operation of the Application Site.
Monitor and analyze usage and trends to improve your experience with the Application Site.
Notify you of updates to the Application Site.
Perform other business activities as needed.
Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
Process payments and refunds.
Request feedback and contact you about your use of the Application Site.
Resolve disputes and troubleshoot problems.
Respond to product and customer service requests.
Send you a newsletter.
Personalize the content and advertising that you see on the Application Site.
Associate your activities, customize content, or tailor advertising across different device and browsers that you use to access the Application Site (for instance, computers, tablets, mobile devices, applications, and websites).
Assisting with other tasks from time to time.
For the purposes of the GDPR, we may use your information in the above ways as this is necessary: (i) to fulfill our obligations under our contract with you or in order to take steps at your request prior to entering into a contract; (ii) for our legitimate interest to maintain our relationship with you or protect you and us against fraud; or (iii) to comply with legal obligations.
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, regulation, or government request. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
Sale or Bankruptcy
Aggregated or De-Identified Information
We do not share your data (including, but not limited to, the personal data of your end users) with third parties for their direct marketing purposes, unless you give us your consent to do so.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
Cookies and Web Beacons
When you access the Application Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.
CONTROLS FOR DO-NOT-TRACK FEATURES
YOUR PRIVACY RIGHTS AND RETENTION OF YOUR INFORMATION
We may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Platform Site or services and for a reasonable period of time afterward. We also may retain your information while it is needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.
You may opt out of any future contacts from us at any time. Additionally, if the collection of your personal data was based on your consent, you have the right to revoke that consent at any time. Be aware that by revoking consent, you may lose access to the services you previously opted to use.
You may request to review, correct, delete, or otherwise modify any of the personal information that you have previously provided to us through the Platform Site and/or services.
You may access and correct certain information about you in accordance with the below Section, “Options Regarding Your Information”.
OPTIONS REGARDING YOUR INFORMATION
You may at any time review or change the information in your account or terminate your account by:
Logging into your account settings and updating your account.
Contacting us using the contact information provided below.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.
Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
Noting your preferences at the time you register your account with the Application.
Logging into your account settings and updating your preferences.
Contacting us using the contact information provided below.
If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below, and we will respond within 30 days as required by law.
If you are under 18 years of age, reside in California, and have a registered account with the Application Site, you have the right to request removal of unwanted data that you publicly post on the Application Site. 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 Application Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
ADDITIONAL GDPR MATTERS FOR USERS IN EUROPE
Access – You have the right to request a copy of the information we are processing about you.
Rectification – You have the right to have incomplete or inaccurate information that we process about you rectified.
Deletion – You have the right to request that we delete information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Restriction – You have the right to restrict our processing of your information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
Portability – You have the right to obtain information we hold about you in a structured, electronic format, and to transmit such data to another data controller, where this is (a) information that you have provided to us, and (b) if we are processing that data solely on the basis of your consent or to perform a contract with you.
Objection – Where the legal basis for processing your information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
Withdrawing consent – If you have consented to our processing of your information, you have the right to withdraw your consent at any time, free of charge. This includes opting out from marketing messages.
You can make a request to exercise any of these rights in relation to your information by sending the request to us at the email address or mailing address set forth under “Contact Us” below. For your own privacy and security, at our discretion, we may require you to provide your identity before providing the requested information. Please note that CSW may take up to 30 days to fulfill such requests.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. A list of local data protection authorities in European countries is available at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Cyber Scent Work, Inc.
3267 Rollings Avenue
Thousand Oaks, CA 91360