Effective as of May 23, 2018
Online Privacy Standards. We follow the principles supported by the Federal Trade Commission’s Fair Information Practices Principles, currently available at https://www.ftc.gov/reports/privacy-online-fair-information-practices-electronic-marketplace-federal-trade-commission.
What This Policy Covers. This policy covers the ways in which PageHabit treats information, including personally identifiable information, which we obtain when you use our Service. We regard “personally identifiable information” as information that someone can use to identify or contact you in person, such as your real name, telephone number, email address, or physical mailing address. Information that we use internally to identify you as a member in our system is not considered personally identifiable information. Your IP address is not considered personally identifiable information.
What This Policy Does Not Cover. This policy does not cover the privacy practices of third parties that we do not own or control, such as third-party payment processing services or our partners and advertisers. In addition, we may provide links to other services and on occasion to other sites that may interest you. All of these sites operate independently of PageHabit and they have their own privacy and security practices. For your best on-line experience, we encourage you to review their policies before submitting any personal information to them.
2: HOW WE COLLECT INFORMATION
Information You Provide During Account Creation
Registration Information. During the membership registration process, we require that you provide us with an email address, your real name, and your physical address. As explained below, though you are required to provide payment information during the registration process, PageHabit does not collect, store, or retain payment information for any member.Access To Your Personal Information. In general, we make it easy for you to view the personally identifiable information we have collected from you. That information is available at your member account page, where you can add, edit, or delete such personally identifiable information as you see fit
Information We Do Not Collect From Any Users
Social Security Number. We do not require your social security number to use the PageHabit Service or to access any part of our site. PageHabit will never ask for your social security number.
Information We Track
Log Files. Similar to many websites and internet services, we gather certain anonymous, non-personal information automatically and store it in web server log files. This information includes internet protocol addresses, browser type, internet service provider (ISP), site entry/exit pages, operating system, date/time stamp, and click stream data. We use this information to improve our site, analyze trends, administer the site, and gather aggregate information about our user base as a whole. Aggregate information is data we collect about a group or category of services or users from which individual user identities have been removed, and therefore does not include your personally identifiable information. We may analyze such data using Google Analytics, or other similar third-party services.
Cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. It can also help us understand how our site visitors click to our site, what pages they view during their visit, and their account and preference information as members of the Service. Similar to many websites, the PageHabit Service may store an encrypted cookie on your computer so we can remember you when you come back without requiring you to log in each time. Cookies also allow us to track and understand the interests of our users to enhance the overall experience on our site. Cookies used by PageHabit do not include your personally identifiable information.
If you prefer not to receive cookies, you can set your web browser software to disable them. To do so, please refer to the help section of your specific browser for more information on how to manage or disable cookies. Please note that your browser must be configured to accept cookies to use the PageHabit Service.
3: HOW WE USE INFORMATION
To Provide You With PageHabit Services
We use your information, including personally identifiable information, for the purposes of providing you with the Service, and with any other PageHabit goods or services you may elect to receive. We share your information, including your personally identifiable information, to the minimum extent necessary. For example, if we are shipping physical goods to you, we will share your name and shipping address with our distribution and shipping partners.
In PageHabit Communications
We use emails and/or prominent notifications on our website as our primary means to inform our users of important Service and promotional announcements
Service-Related Announcements. When you establish an account at http://PageHabit.com, we use the email address provided during account creation to deliver important Service-related announcements to you. Examples of Service-related announcements include: email verification during registration, requests for password reset, important security or server maintenance updates, upgrades, and new releases, or policy changes. These Service-related announcements are considered a fundamental part the PageHabit Service, and members cannot opt-out of these email announcements.
Promotional Announcements. In order to improve the experience for our members, we will send you regular updates from PageHabit from time to time. These communications are enhancements to our service and are entirely optional. We will make it easy for you to unsubscribe from these communications either through the emails themselves or though your account management options page
Gift Subscription Program. If you choose to use our referral tool to tell a friend about the PageHabit Service, or about specific content made available through the Service, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site or to view the content you wish to share. We store this information for the purpose of sending this one-time email, and to track the success of our referral program only. PageHabit will not use this email address for any other purpose.
On Our Website
Site Statistics. As noted above, we use information collected from our web log files to calculate and publish anonymous, non-personal, aggregate statistics that we believe our members are interested in viewing. For example, we may track and publish the total number of members who have signed up for a particular special offer. We publish this data in aggregate form only, and this aggregate data does not contain any personally identifiable information.
For Internal Reporting and Analysis
As noted above, we use information gathered from log files and cookies to improve our site, analyze trends, administer the site, track users' movements around the site, and to gather aggregate information about our user base as a whole.
4: HOW WE SHARE AND DISCLOSE INFORMATION
Sharing, Renting, and Selling Information We Collect. We will neither rent nor sell your personally identifiable information to anyone. Occasionally we share anonymous, non-personal, aggregate information about our members with partners or advertisers, and we may publish these aggregate usage statistics on our website for the interest of our users. This shared or published data does not contain the personally identifiable information of any person.
Linked Services. In some cases, we allow you to access or link to other web services through our website. For example, we allow users to share content using Facebook and Twitter. We make it easy for you to determine when you are accessing or linking to these other web services through our website. In all of these cases, those sites may choose to collect your personal information as they deem appropriate. As noted above, we are not responsible for or in control of how third parties collect, use, or disclose your information obtained through these linked services. We encourage you to be aware when you are using these third party services and, for your best on-line experience, we encourage you to review their policies before submitting any personal information to them.
As Necessary In Certain Legal Circumstances
Legal Requirements. We reserve the right to disclose your information, including personally identifiable information, when we have a good faith belief that access, use, preservation or disclosure of such information is necessary to (a) comply with any law, regulation, legal process or enforceable governmental request, (b) enforce these Terms of Service, including investigation of potential violations of these Terms of Service, © detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of PageHabit, its users, or the public as required or permitted by law.
5: HOW WE KEEP INFORMATION SECURE
Security of Account Information. Your account information is password protected. We will not share your password with anyone. Please do not share your password with anyone, and remember to change your password from time to time, to keep your account information secure.
Network Security. Our partners employ a variety of commercially standard encryption and security technologies and procedures to protect information, including your personal information, unauthorized access. Please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, thus we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.
Management Procedures. Our partners maintain standard physical and electronic procedural safeguards that limit access to your personally identifiable information to employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personally identifiable information.
6: YOUR PERSONAL CHOICES
Receiving Communications. If you subscribe to any optional promotional communications, you will be able to unsubscribe from these communications through your account management options or through the emails we send you.
Editing / Deleting Your Account Information. Any member who establishes a PageHabit Service account can view the personally identifiable information we have collected from that member. That information is available at the member’s account page, where members can add, edit, or delete such personally identifiable information as the member sees fit. To completely delete your account and accompanying personal information, or to delete information about you we may have received from a third party in connection with our Gift Subscription Program, please contact us at support@PageHabit.com. As noted above, though PageHabit does not store payment information for any users, we are able to delete your payment information from our third-party payment provider at your request.
7: GDPR UPDATE
Definitions 1.1 “Data Subject” means any individual about whom Personal Information may be Processed under this Addendum. 1.2 “Data Protection Legislation” means the GDPR (as defined below), together with any national implementing laws in any Member State of the European Union or, to the extent applicable, in any other country, as amended, repealed, consolidated or replaced from time to time. 1.3 “GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. 1.4 “Personal Information” means personal data (as defined under the Data Protection Legislation) that are subject to the Data Protection Legislation and that you authorize PageHabit to collect in connection with PageHabit’s service terms. 1.5 “Process” or “Processing” means any operation or set of operations performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Information. 1.6 “Security Incident” means a breach of security of the Service or PageHabit’s systems used to Process Personal Information leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored or otherwise Processed by PageHabit in the context of this Addendum. 1.7 “Sensitive Information” means Personal Information revealing a Data Subject’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation. 2. Limitations on Use. PageHabit will Process Personal Information solely on your behalf and in accordance with the Agreement, this Addendum and any other documented instructions from you (whether in written or electronic form), or as otherwise required by applicable law. PageHabit is hereby instructed to Process Personal Information to the extent necessary to enable PageHabit to provide the Service in accordance with the Agreement. In case PageHabit cannot process Personal Information in accordance with your instructions due to a legal requirement under any European Union or Member State law to which PageHabit is subject, PageHabit shall (i) promptly notify you in writing (including by e-mail) of such legal requirement before carrying out the relevant Processing, to the extent permitted by the applicable law; and (ii) cease all Processing (other than merely storing and maintaining the security of the affected Personal Information) until such time as you provides PageHabit with new instructions. you will be responsible for providing any necessary notices to, and obtaining any necessary consents from, Data Subjects whose Personal Information is provided by you to PageHabit for Processing pursuant to this Addendum. You acknowledge that the Service are not intended or designed for the Processing of Sensitive Information, and you agree not to provide any Sensitive Information through the Service. 3. Security. PageHabit shall implement, and maintain throughout the term of the Addendum at all times in accordance with then current good industry practice, appropriate technical and organizational measures to protect Personal Information in accordance with Article 32 of the GDPR. On request, PageHabit shall provide you with a written description of the security measures being taken. The Service provides reasonable technical and organizational measures that have been designed, taking into account the nature of its Processing, to assist you in securing Personal Information Processed by PageHabit. 4. Data Subject Requests. You are responsible for handling any requests or complaints from Data Subjects with respect to their Personal Information Processed by PageHabit under this Addendum. PageHabit will notify you promptly and in any event no less than fifteen (15) business days’ notice, unless prohibited by applicable law, if PageHabit receives any such requests or complaints. The Service include technical and organizational measures that have been designed, taking into account the nature of its Processing, to assist customers, insofar as this is possible, in fulfilling their obligations to respond to such requests or complaints. 5. Regulatory Investigations. At your request, PageHabit will assist you in the event of an investigation by a competent regulator, including a data protection regulator or similar authority, if and to the extent that such investigation relates to the Processing of Personal Information by PageHabit on your behalf in accordance with this Addendum. PageHabit may charge a reasonable fee for such requested assistance except where such investigation arises from a breach by PageHabit of the Agreement or this Addendum, to the extent permitted by applicable law. 6. Security Incident. In the event that PageHabit becomes aware of a Security Incident, PageHabit will notify you promptly and in any event no later than forty-eight (48) hours after PageHabit discovers the Security Incident. In the event of such a Security Incident, PageHabit shall provide you with a detailed description of the Security Incident and the type of Personal Information concerned, unless otherwise prohibited by law or otherwise instructed by a law enforcement or supervisory authority. Following such notification, PageHabit will take reasonable steps to mitigate the effects of the Security Incident and to minimize any damage resulting from the Security Incident. At your request, PageHabit will provide reasonable assistance and cooperation with respect to any notifications that you are legally required to send to affected Data Subjects and regulators. PageHabit may charge a reasonable fee for such requested assistance. 7. Sub-Processors. You agree that PageHabit may disclose Personal Information to its subcontractors for purposes of providing the Service (“Sub-Processors”), provided that PageHabit (i) shall enter into an agreement with its Sub-Processors that imposes on the Sub-Processors obligations regarding the Processing of Personal Information that are at least as protective of Personal Information as those that apply to PageHabit hereunder, including requiring the Sub-Processors to only process Personal Information to the extent required to perform the obligations sub-contracted to them, and (ii) shall remain fully liable for all obligations subcontracted to, and all acts and omissions of, the Sub-Processors. If you object to a new Sub-processor, as permitted in the preceding sentence, PageHabit will use reasonable efforts to make available to you a change in the Service or recommend a commercially reasonable change to your configuration or use of the Service to avoid Processing of Personal Data by the objected-to new Subprocessor without unreasonably burdening you. If PageHabit is unable to make available such change within a reasonable period of time, which shall not exceed thirty (30) days, either party may terminate the component of the Service which cannot be provided by PageHabit without the use of the objected-to new Sub-processor by providing written notice to the other party. 8. Data Transfers. In connection with the performance of the Agreement, you authorize PageHabit to transfer Personal Information to the United States. You and PageHabit will enter into Standard Contractual Clauses for the Transfer of Personal Data to Processors Established In Third Countries pursuant to Commission Decision 2010/87/EU of 5 February 2010 Countries ("Model Contract"), attached hereto as Exhibit A. 9. Information. PageHabit shall make available to you all information necessary to demonstrate compliance with the obligations laid down in this Addendum and allow for and contribute to audits, including inspections, conducted by you or an auditor mandated by you. PageHabit shall immediately inform you if, in its opinion, an instruction infringes the Data Protection Legislation. 10. Return or Disposal. Upon termination of your User Account for any reason, PageHabit will return or destroy Personal Information at your request and choice.