GDPR PRIVACY

NOTICE TEMPLATE
Last updated [month day, year]

INTRODUCTION
Thank you for choosing to be part of our community at [business name] (“company”, “we”, “us”,
or “our”). We are committed to protecting your personal information and your right to privacy. If
you have any questions or concerns about our policy, or our practices with regards to your
personal information, please contact us at [contact email].

When you visit our website [website] (“Site”) and use our services, you trust us with your
personal information. We take your privacy very seriously. In this privacy notice, we describe
our privacy policy. We seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some time to
read through it carefully, as it is important. If there are any terms in this privacy policy that you
do not agree with, please discontinue use of our site and our services.

This privacy policy applies to all information collected through our websites (such as [INSERT
URL]), [our mobile] [or] [our Facebook applications] ("Apps"), and/or any related services,
sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").  

Please read this privacy policy carefully as it will help you make informed decisions
about sharing your personal information with us.  

This privacy policy was created using Termly’s Privacy Policy Generator.

TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. DO WE USE GOOGLE MAPS?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
 10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS POLICY?
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us  

In Short: We collect personal information that you provide to us such as name, address,
contact information, passwords and security data, payment information, and social media login
data.

We collect personal information that you voluntarily provide to us when [registering at the Sites
or Apps,] expressing an interest in obtaining information about us or our products and services,
when participating in activities on the Sites [(such as posting messages in our online forums or
entering competitions, contests or giveaways)] or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us
and the Sites, the choices you make and the products and features you use. The personal
information we COLLECT can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone
number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for
authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as
your payment instrument number (such as a credit card number), and the security code associated with
your payment instrument. All payment data is stored by our payment processor and you should review
its privacy policies and contact the payment processor directly to respond to your questions.

[DN: INCLUDE IF USING SOCIAL MEDIA INTEGRATIONS] Social Media Login Data. We provide
you with the option to register using social media account details, like your Facebook, Twitter or other
social media account. If you choose to register in this way, we will collect the Information described in
the section called "Social Logins" [LINK] below.

All personal information that you provide to us must be true, complete and accurate, and you must notify
us of any changes to such personal information.  

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is
collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Sites. This information
does not reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location, information about how and when
you use our Site and other technical information. This information is primarily needed to maintain the
security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. [You can
find out more about this in our Cookies Policy [Hyperlink]].

[DN: FOR MOBILE OR FACEBOOK APPLICATION ONLY:

Information collected through our Apps
In Short: We may collect information regarding your geo-location, mobile device, push notifications, and
Facebook permissions when you use our apps.

If you use our Apps, we may also collect the following information:

 Geo-Location Information. We may request access or permission to and track location-based

information from your mobile device, either continuously or while you are using our mobile
application, to provide location-based services. If you wish to change our access or permissions, you
may do so in your device’s settings.

 Mobile Device Access. We may request access or permission to certain features from your
mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone,
reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish
to change our access or permissions, you may do so in your device’s settings.
 Mobile Device Data. We may automatically collect device information (such as your mobile
device ID, model and manufacturer), operating system, version information and IP address.

 Push Notifications. We may request to send you push notifications regarding your account or the
mobile application. If you wish to opt-out from receiving these types of communications, you may
turn them off in your device’s settings.]

 [Facebook Permissions. We by default access your Facebook basic account information,

including your name, email, gender, birthday, current city, and profile picture URL, as well as other
information that you choose to make public. We may also request access to other permissions
related to your account, such as friends, checkins, and likes, and you may choose to grant or deny
us access to each individual permission. For more information regarding Facebook permissions,
refer to the Facebook Permissions Reference page.]

Information collected from other Sources

In Short: We may collect limited data from public databases, marketing partners, social media
platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing
partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the
information we receive from other sources include: social media profile information (your name, gender,
birthday, email, current city, state and country, user identification numbers for your contacts, profile
picture URL and any other information that you choose to make public); marketing leads and search
results and links, including paid listings (such as sponsored links).

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the
fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below.
We process your personal information for these purposes in reliance on our legitimate business interests
("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your
consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the
specific processing grounds we rely on next to each purpose listed below.  

We use the information we collect or receive:  

[DN: INCLUDE AS APPLICABLE TO THE SITE]

 To facilitate account creation and logon process [with your Consent]. If you choose to link
your account with us to a third party account *(such as your Google or Facebook account), we use
the information you allowed us to collect from those third parties to facilitate account creation and
logon process. See the section below headed "Social Logins" for further information.

 To send you marketing and promotional communications [for Business Purposes and/or
with your Consent]. We and/or our third party marketing partners may use the personal information
you send to us for our marketing purposes, if this is in accordance with your marketing preferences.
You can opt-out of our marketing emails at any time (see the "Your Privacy Rights" below).

 To send administrative information to you [for Business Purposes, Legal Reasons and/or
possibly Contractual]. We may use your personal information to send you product, service and new
feature information and/or information about changes to our terms, conditions, and policies.

 Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill
and manage your orders, payments, returns, and exchanges made through the Sites.

 To post testimonials [with your Consent]. We post testimonials on our Sites that may contain
personal information. Prior to posting a testimonial, we will obtain your consent to use your name
and testimonial. If you wish to update, or delete your testimonial, please contact us at [INSERT
CONTACT] and be sure to include your name, testimonial location, and contact information.

 Deliver targeted advertising to you [for our Business Purposes and/or with your Consent]. We
may use your information to develop and display content and advertising (and work with third parties
who do so) tailored to your interests and/or location and to measure its effectiveness. [For more
information, see our Cookie Policy [HYPERLINK]].

 Administer prize draws and competitions [for our Business Purposes and/or with your
Consent]. We may use your information to administer prize draws and competitions when you elect
to participate in competitions.

 Request Feedback [for our Business Purposes and/or with your Consent]. We may use your
information to request feedback and to contact you about your use of our Sites.
 To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your
information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring
and prevention).

 To enable user-to-user communications [with your consent]. We may use your information in
order to enable user-to-user communications with each user's consent.

 To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or
possibly Contractual].

 To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena
or other legal request, we may need to inspect the data we hold to determine how to respond.

 For other Business Purposes. We may use your information for other Business Purposes,
such as data analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Sites, products, services, marketing and your
experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to
fulfill business obligations.

We only share and disclose your information in the following situations:

 Compliance with Laws. We may disclose your information where we are legally required to do
so in order to comply with applicable law, governmental requests, a judicial proceeding, court
order, or legal process, such as in response to a court order or a subpoena (including in
response to public authorities to meet national security or law enforcement requirements).

 Vital Interests and Legal Rights. We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are involved.
 Vendors, Consultants and Other Third-Party Service Providers. We may share your data
with third party vendors, service providers, contractors or agents who perform services for us or
on our behalf and require access to such information to do that work. Examples include: payment
processing, data analysis, email delivery, hosting services, customer service and marketing
efforts. We may allow selected third parties to use tracking technology on the Sites, which will
enable them to collect data about how you interact with the Sites over time. This information may
be used to, among other things, analyze and track data, determine the popularity of certain
content and better understand online activity. Unless described in this Policy, we do not share,
sell, rent or trade any of your information with third parties for their promotional purposes.

 Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of
our business to another company.

 Third-Party Advertisers. We may use third-party advertising companies to serve ads when you
visit the Sites. These companies may use information about your visits to our Website(s) and
other websites that are contained in web cookies and other tracking technologies in order to
provide advertisements about goods and services of interest to you. [See our Cookie Policy
[Hyperlink] for further information]

 Affiliates. We may share your information with our affiliates, in which case we will require those
affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries,
joint venture partners or other companies that we control or that are under common control with
us.

 Business Partners. We may share your information with our business partners to offer you
certain products, services or promotions.

 With your Consent. We may disclose your personal information for any other purpose with your
consent.

 Other Users. When you share personal information (for example, by posting comments,
contributions or other content to the Sites) or otherwise interact with public areas of the Site [or
App], such personal information may be viewed by all users and may be publicly distributed
outside the Site [and our App] in perpetuity. [If you interact with other users of our Sites and
register through a social network (such as Facebook), your contacts on the social network will
 see your name, profile photo, and descriptions of your activity.] Similarly, other users will be able
to view descriptions of your activity, communicate with you within our Sites, and view your
profile.

[FOR MOBILE APPLICATION ONLY:

 Offer Wall. Our Apps may display a third-party hosted “offer wall.” Such an offer wall allows
third-party advertisers to offer virtual currency, gifts, or other items to users in return for
acceptance and completion of an advertisement offer. Such an offer wall may appear in our
mobile application and be displayed to you based on certain data, such as your geographic area
or demographic information. When you click on an offer wall, you will leave our mobile
application. A unique identifier, such as your user ID, will be shared with the offer wall provider in
order to prevent fraud and properly credit your account.]

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Policy [HYPERLINK TO POLICY].

DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the
Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to
this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. [By using
our implementation of the Google Maps APIs, you agree to allow us to gain access to information about
you including personally identifiable information (such as usernames) and non-personally identifiable
information (such as location). [We will be collecting the following information:   ] (information list)
For a full list of what we use information for, please see the previous sections titled “Use of Your
Information” and “Disclosure of Your Information.” [You agree to allow us to obtain or cache your
location. You may revoke your consent at anytime.] [We use information about location in conjunction
with data from other data providers.]

[The Maps APIs that we use store and access cookies and other information on your devices. If you are
a user currently in the European Union, please take a look at our EU User Consent Policy, which can be
found at this link: [link from question].]

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have
access to certain information about you.

Our Sites offers you the ability to register and login using your third party social media account details
(like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile
information about you from your social media provider. The profile Information we receive may vary
depending on the social media provider concerned, but will often include your name, e-mail address,
friends list, profile picture as well as other information you choose to make public. [If you login using
Facebook, we may also request access to other permissions related to your account, such as friends,
check-ins, and likes, and you may choose to grant or deny us access to each individual permission.]

We will use the information we receive only for the purposes that are described in this privacy policy or
that are otherwise made clear to you on the Sites. Please note that we do not control, and are not
responsible for, other uses of your personal information by your third party social media provider. We
recommend that you review their privacy policy to understand how they collect, use and share your
personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?  

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in [INSERT DETAILS]. If you are accessing our Sites from outside [INSERT
LOCATION OF SERVERS], please be aware that your information may be transferred to, stored, and
processed by us in our facilities and by those third parties with whom we may share your personal
information (see "Disclosure of Your Information" above), in [INSERT DETAILS OF DESTINATION
COUNTRIES] and other countries .

If you are a resident in the European Economic Area, then these countries may not have data protection
or other laws as comprehensive as those in your country. We will however take all necessary measures
to protect your personal information in accordance with this privacy policy and applicable law.

Option 1: European Commission's Standard Contractual Clauses (use this if you choose model clauses
as a ground for international transfers): Such measures implementing the European Commission's
Standard Contractual Clauses for transfers of personal information between our group companies and
between us and our third-party providers, which require all such recipients to protect personal
information that they process from the EEA in accordance with European data protection laws. [Our
Standard Contractual Clauses can be provided upon request / are available here [link]]. We have
implemented similar appropriate safeguards with our third party service providers and partners and
further details can be provided upon request.

OR

Option 2: EU-U.S. Privacy Shield Framework (use this if you choose the Privacy shield framework as a
ground for international transfers:

In particular [COMPANY] complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of personal information transferred
from the European Union to the United States and has certified its compliance with it. As such,
[COMPANY] is committed to subjecting all personal information received from European Union (EU)
member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable
Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s
Privacy Shield List.

[COMPANY] is responsible for the processing of personal information it receives, under the Privacy
Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework,
[COMPANY] is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we
may be required to disclose personal information in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.

OR

Option 3: Binding Corporate Rules (use this if you choose to implement Binding Corporate Rules):

These include, a set of Binding Corporate Rules ("BCRs") established and implemented by
[COMPANY]. Our BCRs have been recognized by EEA data protection authorities as providing an
adequate level of protection to the personal information we process internationally. You can find a copy
of our BCRs here [INSERT LINK].]

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party
providers who advertise, but are not affiliated with, our websites.

The Sites may contain advertisements from third parties that are not affiliated with us and which may link
to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of
data you provide to any third parties. Any data collected by third parties is not covered by this privacy
policy. We are not responsible for the content or privacy and security practices and policies of any third
parties, including other websites, services or applications that may be linked to or from the Sites. You
should review the policies of such third parties and contact them directly to respond to your questions.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this
privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this
privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting
or other legal requirements). No purpose in this policy will require us keeping your personal information
for longer than [90 days/6 months/1 year/2 years/the period of time in which you have an account with
us/90 days past the termination of your account/6 months past the termination of your account/1 year
past the termination of your account/2 years past the termination of your account].

When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize it, or, if this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical
security measures.

We have implemented appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, please also remember that we cannot
guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal
information, transmission of personal information to and from our Sites is at your own risk. You should
only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites,
you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent
to such minor dependent’s use of the Site [and App]. If we learn that personal information from users
less than 18 years of age has been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become aware of any data we have
collected from children under age 18, please contact us at [INSERT CONTACT EMAIL].

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: [In some regions, such as the European Economic Area, you have rights that allow you
greater access to and control over your personal information.] You may review, change, or terminate
your account at any time.

[In some regions (like the European Economic Area), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal
information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the
right to object to the processing of your personal information. To make such a request, please use the
contact details provided below [HYPERLINK]. We will consider and act upon any request in accordance
with applicable data protection laws. 
If we are relying on your consent to process your personal information, you have the right to withdraw
your consent at any time. Please note however that this will not affect the lawfulness of the processing
before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here: [Link]
protection/bodies/authorities/index_en.htm] ]

[Account 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
 [Other]
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 of Use and/or comply with legal
requirements.]

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you
prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you
choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To
opt-out of interest-based advertising by advertisers on our Site visit [Link]
[For further information, please see our Cookie Policy [HYPERLINK]]

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by
clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided
below. You will then be removed from the marketing email list – however, we will still need to send you
service-related emails that are necessary for the administration and use of your account. You can also
opt-out by:
 Noting your preferences at the time you register your account with the Sites.
 Logging into your account settings and updating your preferences.
 Contacting us using the contact information provided below
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to
your personal information.

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.

If you are under 18 years of age, reside in California, and have a registered account with the [Sites/
Mobile Application/ Facebook Application], you have the right to request removal of unwanted data that
you publicly post on the [Sites/ Mobile Application/ Facebook Application]. 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 [Sites/ Mobile Application/ Facebook Application], but please be aware that
the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an
updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make
material changes to this privacy policy, we may notify you either by prominently posting a notice of such
changes or by directly sending you a notification. We encourage you to review this privacy policy
frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us [Our Privacy Officer] at [INSERT
CONTACT EMAIL] or by post to:

[Company Name]
[PRIVACY OFFICER]
[Street Address]
[City, State Zip]

[If you are a resident in the European Economic Area, the "data controller" of your personal information
is [INSERT NAME OF THE COMPANY]. [COMPANY, has appointed [INSERT NAME] to be its
representative in the EEA. You can contact them directly regarding the processing of your information by
COMPANY, by email at [INSERT CONTACT EMAIL] or by post to: [INSERT ADDRESS].]

If you have any further questions or comments about us or our policies, email us at [CONTACT EMAIL]
or contact us by post at:

Company address
[Street Address]
[City, State Zip]