dragas.co. ("Company" or “dragas.co”) is the
developer and
operator of
various content websites (“website”),
providing resources, information and comparison about various goods and services owned or
operated by our
third-party partners (“Partners”), as well as additional features, as
offered from time to
time, including,
enabling our websites’ user to easily be directed to our Partner’s digital assets
(“Partner
Site”) to
directly interact with them regarding their products and offers (collectively
“Services”).
This Privacy Policy (“Privacy Policy”), describe how dragas.co collect, use
and
disclose certain
information,
including Personal Data (as defined below) when users (“user” or
“you”)
access, browse and interact with our
websites, and the rights you have with regards to your information. This Privacy Policy
further explains how
we safeguard your Personal Data and how you may exercise your rights related to your
Personal Data, among
others, and where applicable, as required according to the EU General Data Protection
Regulation
(“GDPR”), the California Consumer Privacy Act of 2018 and as amended by the
California Privacy Rights Act of 2020 effective January 1, 2023
("CPRA") (collectively “CCPA”), and other US data
protection laws, federal laws, state laws, etc., (all collectively shall be referred to as
"Privacy Legislation").
This Privacy Policy is an integral part of our Terms of
Use. Definitions used herein but not defined herein
shall have the meaning ascribed to them in the Terms of Use.
We want to enable you to freely decide whether you wish to use our Services or provide us
with any
information which may be required or obtained, and therefore, we encourage you to read this
Privacy Policy
carefully and use it to make informed decisions.
You are not required by law to provide us with any Personal Data. Sharing
your Personal Data with us is entirely voluntary. However, without your data, we would not
always be able to provide you with all or some of our services.
(1) POLICY AMENDMENTS:
We reserve the right to amend this Privacy Policy from time to time, at our sole
discretion. The most
recent
version of this Privacy Policy will always be posted on the website and the update date
will be
reflected in
the “Last Revised” heading. We will provide notice if these changes are material and,
where required by
applicable law, we will obtain your consent. Any amendments to the Privacy Policy will
become effective
within 30-days upon the display of the modified Privacy Policy. We recommend you to
review this Privacy
Policy periodically to ensure that you understand our most updated privacy practices
(3) DATA COLLECTED BY dragas.co & PURPOSE OF
USE
We may collect two types of information from you, depending on your interaction with us
and our
website:
“Non-Personal Data” meaning aggregated, non-personal
non-identifiable
information, which
may be made available or gathered via your access to the website and use of the
Services. We are not
aware of the identity of the user from which the Non-Personal Data is collected. Such
Non-Personal Data
may include aggregated usage information and technical information transmitted by your
device, such as
browser version, operating system type and version, device settings, and software data.
“Personal Data” or “Personal
Information” meaning
individually
identifiable information, namely information that identifies an individual or may, with
reasonable
effort, be used to identify an individual.
For the avoidance of doubt, in the event we link or connect Non-Personal Data to Personal
Data, the
combined data set shall be treated as Personal Data as long as such connection or
linkage exists.
We do not knowingly collect or process any Personal Data constituting or revealing racial
or ethnic
origin, political opinions, religious or philosophical beliefs, or trade union
membership, genetic data,
biometric data, data concerning a person's health or data concerning a person’s sex life
or sexual
orientation (“Special Categories of Personal Data”).
The table below provides detailed information regarding the specific
types and data sets
of
Personal Data we collect and process, the purpose for which we collect and use such
data, as well as
our lawful basis for processing Personal Data (where the GDPR applies)
| Types of Data |
Purposes of Collection & Use |
Lawful Basis Under the GDPR |
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Online Identifiers
When users interact with our website, we collect online identifiers
associated or transmitted
from the user’s browser and device, such as Internet Protocol (IP)
address and Cookie ID, and in addition,
when you access our website or otherwise interact with content or
features that enables you to be directed to our Partner’s Sites,
we will assign to your browser a unique online identifier, randomly
generated by us (“Unique ID” and collectively
“Online Identifiers”).
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Online Identifiers are collected through automatic tools such as cookies,
owned and operated
by us (known as “first party”), or of our service providers (known as
“third party”) and are
used for various purposes, such as, to operate our website and enable
its proper
functionality, for security, fraud detection and to resolve technical
issues, to enhance
your experience such as to automatically recognize your preferred
language, for our internal
analytic purpose in order to examine site traffic and marketing
campaigns performance, as
well as for advertising purpose, including retargeting based on your
visits in our
website.
In addition, the Unique ID is used by us for the purpose of tracking the
traffic flow in our
website or otherwise directed from our websites to our Partner Site, in
order to manage our
business engagement, and for example analyze performance, business
transactions and track
conversation.
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Where we collect Online Identifiers for operation and security purposes
(for example cookies
defined as “strictly necessary”), we process your data based on our
legitimate interest.
Where we collect Online Identifiers for analytic and advertising
purposes, we process the
data based on your consent which we will obtain through our cookie
notice and consent
management. You may withdraw consent at any time by using the cookie
preference settings.
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Usage Data
When users access and interact with our website, we collect usage data,
which includes
information such as how you interact with our webpage, time, duration of
use, pages you have
viewed on our website click stream in the website, the referring URL
(that is, the webpage
or ads directing you to our website), and which Partners’ Sites you were
directed to. We may
further receive information from our Partners, indicating if you have
chosen to interact or
otherwise purchase or obtain their services and products (collectively
“Usage
Data”).
In addition, as some of our websites may contains offers relating to
individuals' health
(e.g. offers of medical devices or health related products),
by processing Usage Data, and specially the Partners' Sites you were
directed to,
we may be provided with insights regarding users' potential medical
situation ("Health-Related Data").
However, it is important to note that we do not process any Protected
Health Information (PHI) directly from users,
as such terms defined under the Health Insurance Portability and
Accountability Act (HIPAA).
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Usage Data is associated with Online Identifiers and collected by
automatic tools as detailed
above. We use Usage Data to enhance your experience and improve our
Services, content and
marketing campaigns, and for our internal analytic purpose as well as
remarket our Services
to people who have taken some action on the website.
In addition, the Usage Data provided by our Partners is used to manage
our business
transactions with Partners and track conversion.
We will use the Health-Related Data solely to manage our business
transactions with Partners and track conversion.
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We process Usage Data based on your consent which we will obtain through
our cookie notice
and consent management. You may withdraw consent at any time by using
the cookie
preference
settings.
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Contact Information
In the event you contact us with any inquiries, either through
an online form available on
the website, by sending us an email or by any other means, you will be
requested to provide
us certain information such as your name, telephone number, company name
and position, email
address, Health-Related Data, etc., and as applicable to your inquiry
(“Contact Information”).
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We will use your Contact Information solely for the purpose of responding
to your
inquiries.
Our correspondence with you may be processed and stored by us in order to
improve our
customer services and in the event we believe it is required to further
retain it, for
example, in the event of any claims or in order to provide you with any
further assistance
(if applicable).
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We process Contact Information and our correspondence subject to our
legitimate interest.
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Newsletter Subscription
If you subscribe to our newsletter or to receive other marketing
materials, you will be
requested to provide us with your name and email address.
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We will use this information solely to provide you with the content you
have requested.
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We process such information based on your consent. You may withdraw
consent at any time
through the “unsubscribe” link within the email you
will receive or by
contacting us
directly.
If you unsubscribe, we further retain your email address however solely
as part of our
opt-out list, based on our legitimate interest and solely to ensure we
comply with such
preference and choice (meaning so we will know not to send you marketing
materials).
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Survey
If you voluntarily choose to participate in our surveys, you will be
request to fill out our
forms and might be requested to provide us with your name, email, and
additional information
as requested during such participation, depending on the type of survey,
and may include
details regarding your age group, shopping preferences, etc.
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We use this information to evaluate your applicability to our survey,
improve and enhance our
Service, as well as optimize and customize the Services.
Where applicable (depending on the type of survey) we will also use this
information in order
to send you the applicable gift card or coupon, etc.
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We process the information you will provide while participating and
filling out our survey
forms, based on your consent. You may withdraw your consent at any time
by contacting us, as
detailed under this Privacy Policy.
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User Review, Posting Comments and Q&As
If you choose to submit to our website, reviews, comments or post a
question (collectively
“User Generated Content”) you may be requested, through
the submission
process, to provide
your name and email address, as well as additional information (some are
optional) such as
your Gravatar or social media profile (including where the submission
was made through your
User Account, as detailed below), job title, industry, etc.
If we will decide to publish your User Generated Content, it may be
posted under your details
such as the name or nickname you have provided us or your Gravatar or
social media
profile.
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We will use this information for authentication and validation purposes
(for example to
conform you are a real person), as well as to publish your User
Generated Content, and we
may send you an email notifying you other user have responded to your
User Generated
Content.
Note that, we recommend you do not disclose additional Personal Data
through your User
Generated Content, as such content might be publicly posted and we
cannot control any third
party's use of such information.
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We process User Generated Content and the information you provide while
submitting such
content subject to our legitimate interest.
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User Account:
To use some or participate in some of our Services, and depending on the
website you interact
with, you will be requested to register and open an account
(“User Account”).
During the
registration process you will be requested to provide us with certain
information such as
your full name, email address, and other similar contact information, as
well as to create a user name and password.
If you choose to connect through a social media account (i.e., Facebook,
G+ or LinkedIn), we
may obtain certain information about you as stored therein (e.g., full
name, e-mail, profile
picture and any other information which you made public).
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We use the information provided when you create a User Account to
designate your account,
authentication and validation, provide account management, support and
to provide the
applicable Services.
In addition, we use this information to send you marketing related
communications (by email
or other contact details you have provided), materials and content
regarding the Services
you are currently using or any services we may offer in the future to
keep you up to date,
and for example, offers and content such as new features available in
the website, surveys,
etc.
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We process the information you provide through registration for the
purpose of performing our
contract with you.
Processing of information for direct marketing purposes is made subject
to our legitimate
interest. You can opt-out at any time using the
“unsubscribe” option within
the body of the
message.
Please note that if you choose to unsubscribe from our marketing list, we
will still retain
your contact details and send you service-related emails, such as offers
you have requested
to receive.
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Contacting Third Party:
If you voluntarily contact an applicable service provider of Third-Party
Services through the unique telephone numbers
displayed on our websites you will be assigned with a unique caller ID.
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We will use this information, in order to audit our affiliates and
calculate payments.
We will not combine this data with Personal Data.
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We process this information subject to our legitimate interest.
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Request for a Call Back or a Quote:
If you voluntarily fill out and submit our online form in request to
receive information or a
quote directly from our Partners or by us on behalf of our Partners, you
will be requested
to provide us with you Contact Information as well as additional
information related to the
service or product you are interested in.
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We will use the information you voluntarily provide us in order to match
you with the Partner
we believe to be applicable to your needs, where you have provided your consent.
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We process this information subject to our legitimate interest.
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Push Notifications:
If you voluntarily subscribe to receive Push Notification on
our behalf, we (directly or by
our service providers) will process your IP address and approximate
geographical location
(country).
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We will use this information solely for the purpose of sending you with
the notifications you
subscribed to receive.
You may unsubscribe from receiving push notifications, at any time,
through your standard
browser settings.
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We process this information subject to your consent.
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Please note that the actual processing operation per each purpose of use and lawful basis
detailed in the
table above may differ. Such processing operation usually includes a set of operations
made by automated
means, such as collection, storage, use, disclosure by transmission, erasure, or
destruction. The
transfer of Personal Data to third-party countries, as further detailed in the
Transfer of Data
section
below, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or
illegal activities,
fraud, misappropriation, infringements, identity thefts, and any other misuse of the
Services and to
enforce the Terms, as well as to protect the security or integrity of our databases and
the Services,
and to take precautions against legal liability. Such processing is based on our
legitimate
interests.
We may collect different categories of Personal Data and Non-Personal Data from you,
depending on the
nature of your interaction with the Services provided through the website and Platform,
as detailed
above.
(5) COOKIES & TRACKING TECHNOLOGIES
We use “cookies” (or similar tracking technologies) when you access the website or
interact with the
Services we offer. The use of cookies is a standard industry-wide practice. A “cookie”
is a small piece
of information that a website assigns and stores on your computer while you are viewing
a website.
Cookies can be used for various purposes, including allowing you to navigate between
pages efficiently,
for statistical purposes, as well as for advertising purposes. You can find more
information about our
use of cookies here: www.allaboutcookies.org.
In addition, please see our Cookies Settings page
which
details the cookies we use on are
website, as well as enabling you to change your settings and preferences ant any time.
Most browsers will allow you to erase cookies from your computer’s hard drive, block
acceptance of
cookies, or receive a warning before a cookie is stored. You may set your browser to
block all cookies,
including cookies associated with our website and Services, or to indicate when a cookie
is being used
by us, by adjusting the privacy and security settings of your web browser. Please refer
to the support
page of your browser to learn more about how you can adjust your privacy and security
settings.
Additionally, you may opt out of certain advertisers’ cookies and browser-enabled,
interest-based
advertising.
Please note that once you choose to opt out or disable cookies, some features of the
Services may not
operate properly and your online experience may be limited. In addition, even if you do
opt-out, you may
still receive some content and advertising, however, it will not be targeted content or
advertising.
Please note that, where we use third-party advertising cookies, such third-party may
independently
collect, through the use of such tracking technologies, some or all types of Personal
Data detailed
above, as well as additional data sets, including to combine such information with other
information
they have independently collected relating to your online activities across their
network of websites,
for the purpose of enhanced targeting functionality and delivering personalized ads, as
well as
providing aggregated analytics related to the performance of our advertising campaign
you interacted
with. These third parties collect and use this information under their own privacy
policies, and are
responsible for their practices.
For additional information, please see the Your Rights Related to Your Personal Data
&
Opt-Outem
section below.
(6) YOUR RIGHTS RELATED TO YOUR PERSONAL DATA
& OPT-OUT
We respect your privacy and acknowledge that different users may have different privacy
preferences. We
enable you to exercise certain choices, rights, and controls in connection with your
Personal Data that
we hold. Depending on your relationship with us, your jurisdiction and the applicable
data protection
laws that apply to you, you have the right to request certain limitations or rights to
be executed.
For detailed information on your rights related to your Personal Data and to further
request to exercise
such rights, please send us an e-mail HERE and send it to
our
privacy team at: contact@dragas.co
For California residents, please see our CCPA Privacy
Notice.
Certain rights can be easily executed independently by you without the need to fill out
the DSR Form:
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If you have a User Account, you can correct certain data provided therein (such
as contact
information) through the account settings;
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You can you can opt-out from receiving our marketing emails by clicking
“unsubscribe” link;
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You can use the Cookie Settings tool on
our
website to change
your preferences;
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You may opt-out directly from third party retargeting cookies or other
ad-technology trackers
through self-regulatory services. For more information, please visit: Digital
Advertising
Alliance (US) HERE; Digital
Advertising Alliance (Canada)
HERE; Digital
Advertising
Alliance
(EU) HERE; Network Advertising Initiative HERE;
Use the
Global Privacy
Control signals.
You can
also opt out of interest-based advertising with some of the service providers we
use, such as
Google HERE, Google
Analytic
HERE.
(7) DATA RETENTION
We retain Personal Data we collect as long as it remains necessary for the purposes set
forth above, all
in accordance with applicable laws, or until an individual expresses a preference to
opt-out.
Other circumstances in which we will retain your Personal Data for longer periods of time
include: (i)
where we are required to do so in accordance with legal, regulatory, tax, or
accounting requirements;
(ii) for us to have an accurate record of your dealings with us in the event of any
complaints or
challenges; or (iii) if we reasonably believe there is a prospect of litigation relating
to your
Personal Data. Please note that except as required by applicable law, we may at our sole
discretion,
delete or amend information from our systems, without notice to you, once we deem it is
no longer
necessary for such purposes.
(8) SECURITY
Data security is of high priority to us. We make efforts to protect Personal Data we
process from
unauthorized access or unauthorized alteration, disclosure or destruction. We have
implemented physical,
technical and administrative security measures for the website that comply with
applicable laws and
industry such as restricting access to Personal Data to our personnel, minimize the data
that we store
on our servers, etc. Note that, we cannot be held responsible for unauthorized or
unintended access that
is beyond our control, and we make no warranty, express, implied or otherwise, that we
will always be
able to prevent such access.
Please contact us at: contact@dragas.co if you feel
that your
privacy was not dealt with properly, in a way that was in breach of our Privacy Policy
or if you become
aware of a third party's attempt to gain unauthorized access to any of your Personal
Data. We will make
a reasonable effort to notify you and the appropriate authorities (if required by
applicable law) in the
event that we discover a security incident related to your Personal Data.
(9) TRANSFER OF DATA
Due to our global operation, we may store or process your Personal Data in various
territories, including
the EU, the United States or in other countries. Thus, any information you provide us
may be transferred
to and processed in countries other than the country from which you accessed our
Services. We will take
appropriate measures to ensure that your Personal Data receives an adequate level of
data protection
upon its transfer. When Personal Data that was collected within the EEA is transferred
outside the EEA,
we will take necessary steps in order to ensure that sufficient safeguards are provided
during the
transferring of such Personal Data. You may exercise your rights, where applicable, to
receive
information regarding the transfer mechanism that was used during such transfer.
Personal Data
transferred outside the EEA is transferred, in all cases pursuant to standard
contractual clauses
approved by the European Union ("SCCs"), and similar mechanism is
implemented for
transferring data
outside the UK, or other contractual clauses that will ensure the security of the
Personal Data (pending
an adequacy decision from the European Commission).
(10) ELIGIBILITY AND CHILDREN PRIVACY:
Our website and Services are not intended for use by children (the phrase "child" shall
mean an
individual that is under the age defined by applicable law which with respect to the EEA
is under the
age of 16 and with respect to the US, under the age of 13). Furthermore, some of our
websites are
restricted for use for minors (as defined under applicable law). Thus, we do not
knowingly process
children’s information. We will discard any information that we receive from a user that
is considered a
"child" immediately upon our discovery that such a user shared information with us.
Please contact us
at: contact@dragas.co if you
have reason to believe
that a
child has shared any information with us,
and we will take reasonable steps to ensure that such information is deleted from our
files.
(11) JURISDICTION-SPECIFIC NOTICES:
A. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. Pursuant to the California Consumer
Privacy Act of 2018 (“CCPA”)
effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Please see the CCPA Privacy Notice which discloses the categories of personal
information collected,
purpose of processing, source, categories of recipients with whom the personal
information is shared for a business purpose,
whether the personal information is sole or shared, the retention period, and how to
exercise your rights as a California resident.
B. ADDITIONAL NOTICE TO COLORADO RESIDENTS
Under the Colorado Privacy Act (“CPA”) if you are a resident of
Colorado, acting only as an individual or household context (and
not in a commercial or employment context, as a job applicant or as a
beneficiary of someone acting in an employment context), your rights with respect to
your personal data are described below.
“Personal Data” as defined in the CPA means: “information that is
linked or reasonably linkable to an identified or identifiable individual”
and does not include any of the following: publicly available
information, de-identified or aggregated consumer, and information excluded from the
CPA scope,
such as: Health or medical information covered by the Health Insurance Portability
and Accountability Act of 1996 (HIPPA) or 42 CFR Part 2- “Confidentiality Of
Substance Use Disorder Patient Records”,
Personal information covered by certain sector-specific privacy laws, including the
Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or and the
Driver’s Privacy Protection Act of 1994,
Children’s Online Policy Protection Act of 1998 (COPPA), Family Educational Rights
and Privacy Act of 1974, national Security Exchange Act of 1934, higher education
data and employment data.
Sensitive Data includes (i) racial or ethnic origin,
religious beliefs, mental or physical health condition or diagnosis, sex life or sexual
orientation; (ii) Genetic or biometric data that
can be processed to uniquely identify an individual; or (iii) child
data. We do not process or collect any sensitive data.
Section 3 “DATA COLLECTED BY dragas.co & PURPOSE OF
USE” of the Privacy Policy, we
describe our collection and processing of personal data, the categories of personal data
that are collected or processed, and the purposes.
YOUR RIGHTS UNDER CPA:
Herein below, we will detail how consumers can exercise their rights, and appeal such
decision, or if dragas.co sells the personal data, or sells the personal data for
advertising
and how to opt-out.
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Right to Access/ Right to Know
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You have the right to confirm whether and know the Personal Data we
collected on you
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You can exercise your right by reviewing this Privacy Policy, in case you
would like to receive the Personal Data please send us an e-mail form to receive a copy of your data
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Right to Correction
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You have the right to correct inaccuracies in your Personal Data, taking
into account the nature of the Personal Data and the purposes of the
processing of your Personal Data.
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You can exercise this right by sending us an e-mail form
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Right to Deletion
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You have the right to delete the Personal Data, this right is not
absolute and in certain circumstances we may deny such request.
We may deny your deletion request, in full or in part, if retaining the
information is necessary for us or our service provider(s) for any of
the following reasons:
(1) Complete the transaction for which we collected the
Personal Data, provide a good or service that you requested, take
actions reasonably anticipated within the context of our ongoing
business relationship with you,
fulfill the terms of a written warranty or product recall conducted in
accordance with federal law, or otherwise perform our contract with you;
(2) Detect security incidents, protect against
malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities;
(3) Debug products to identify and repair errors that
impair existing intended functionality; (4)
Exercise free speech, ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law;
(5) Comply with the law or legal obligation;
(6) Engage in public or peer-reviewed scientific,
historical, or statistical research in the public interest that adheres
to all other applicable
ethics and privacy laws, when the information’s deletion may likely
render impossible or seriously impair the research’s achievement, if you
previously provided informed consent;
(7) Enable solely internal uses that are reasonably
aligned with consumer expectations based on your relationship with us;
(8) Make other internal and lawful uses of that
information that are compatible with the context in which you provided
it.
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If you would like to delete your Personal Data please send us an e-mail form
You do not need to create an account with us to submit a request to know
or delete.
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Right to Portability
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You have the right to obtain the personal data in a portable, and to the
extent technically feasible, readily usable format that allows you to
transmit the data to another entity without hindrance.
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If you would like to receive the Personal Data please send us an e-mail form to receive a copy of your data we will select a
format to provide your Personal Data that is readily usable and should allow
you to transmit the information from one entity to another entity without
hindrance.
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Right to opt out from Profiling
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We do not profile you, thus we do not need to provide an opt-out.
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Right to Appeal
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If we decline to take action on your request, we shall so inform you
without undue delay, within 45 days of receipt of your request.
The notification will include a justification for
declining to take action and instructions on how you may
appeal.
If we deny the appeal, you may contact the Colorado Attorney General
using this link: https://coag.gov/office-sections/consumer-protection/
or (720) 508-6000.
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Not more than 60 days after receipt of an appeal we will
inform you in writing of any action taken or not taken in response to
the appeal, including a written explanation of the reason for the
decisions.
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Duty not to violet the existing laws against discrimination or
non-discrimination
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Such discrimination may include denying a good or service, providing a
different level or quality of service, or charging different prices.
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We do not discriminate our users.
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HOW TO SUBMIT A REQUEST UNDER CPA?
Only you, or someone legally authorized to act on your behalf, may make a request to
know or delete related to your Personal Data. If the
e-mail
is submitted by someone other than the consumer about whom information is being
requested, proof of authorization (such as power of attorney or probate documents) will
be required.
We will respond to your request within 45 days after receipt of a verifiable Consumer
Request and for no more than twice in a twelve-month period.
We reserve the right to extend the response time by an additional 45 days when
reasonably necessary and provided consumer notification of the extension is made within
the first 45 days.
If we refuse to take action on a request, you may appeal our decision
within a reasonable period time by contacting us at privacy@adcore.com and specifying you wish to
appeal. Within 60 days of our receipt of your appeal,
we will inform you in writing of any action taken or not taken in response to the
appeal, including a written explanation of the reasons for the decisions.
If the appeal is denied, you may submit a complaint as follows: Colorado AG at https://coag.gov/file-complaint/
If you have an account with us, we may deliver our written response to that account or
via email at our sole discretion. If you do not have an account with us, we will deliver
our written response by mail or electronically, at your option. You do not need to
create an account for submitting a request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of
your request. The response we provide will also explain the reasons we cannot comply
with a request, if applicable.
C. ADDITIONAL NOTICE TO VIRGINIA RESIDENTS
Under the Virginia Consumer Data Protection Act, as amended (“VCDPA”) if
you are a resident of Virginia acting in an individual or household context (and
not in an employment or commercial context), you have the following
rights with respect to your Personal Data.
"Personal data" means any information that is linked or reasonably
linkable to an identified or identifiable natural person. "Personal data" does
not include de-identified data or publicly available information.
Personal Data does not include de-identified data or publicly available data, and
information excluded from the scope such as: HIPAA, GBPA, non-profit entities, higher
education, employment data and FCRA, Driver's Privacy Protection Act of 1994, Family
Educational Rights and Privacy Act, Farm Credit Act.
The VCDPA requires dragas.co discloses the Categories of data processing and the purpose
of
each category, as detailed in Section 3 “DATA COLLECTED BY dragas.co & PURPOSE OF USE” of
the Privacy Policy. Disclosure of sale of data or
targeted advertising are detailed in Section 6 “YOUR RIGHTS RELATED TO YOUR PERSONAL
DATA & OPT-OUT” above, and in the e-mail. Further, the table above under “ADDITIONAL NOTICE TO COLORADO RESIDENTS”
details the rights you have under VCDPA and how you may exercise your rights.
HOW TO SUBMIT A REQUEST UNDER VCDPA?
We shall respond to your request within 45 days of receipt. We reserve the right to extend
the response time by an additional 45 days when reasonably necessary and provided consumer
notification of the extension is made within the first 45 days. If we refuse to take action
on a request, you may appeal our decision within a reasonable period time by contacting us
at contact@dragas.co and specifying you wish to
appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any
action taken or not taken in response to the appeal, including a written explanation of the
reasons for the decisions. If the appeal is denied, you may submit a complaint as follows:
Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform
We shall provide information in response to your request free of charge, up to twice
annually, unless requests are manifestly unfounded, excessive or repetitive. If we are
unable to authenticate your request using commercially reasonable efforts, we may
request additional information reasonably necessary to authenticate you and your
request. If we cannot authenticate you and your request we will not be able to grant
your request.
D. ADDITIONAL NOTICE TO CONNECTICUT RESIDENTS
Under the Connecticut Data Privacy Act, Public Act. No. 22-14 (the
“CDPA”) if you are a resident of Connecticut, acting in an individual
or household context (and not in a commercial or employment context or
as a representative of business, non-profit or governmental entity), your rights with
respect to your personal data are described below.
"Personal data" means any information that is linked or reasonably
linkable to an identified or identifiable individual. It does not
include de-identified data or publicly available information. If further does not
include information excluded from the scope such as: HIPAA, GBPA, non-profit entities,
higher education, employment data and FCRA, Driver's Privacy Protection Act of 1994,
Family Educational Rights and Privacy Act, Farm Credit Act.
The categories of personal data processed, purpose of processing, are detailed in Section
3 “DATA COLLECTED BY dragas.co & PURPOSE OF USE”.
Disclosure of sale of data or targeted advertising
are detailed in Section 6 “YOUR RIGHTS RELATED TO YOUR PERSONAL DATA & OPT-OUT”
above, and in the e-mail DSR Form.
Instructions on how to exercise your rights are detailed in the table above under
“ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the rights you have under CDPA and how
you may exercise your rights.
HOW TO SUBMIT A REQUEST UNDER CDPA?
We shall respond to your request within 45 days of receipt. The response period may be
extended once by 45 additional days when reasonably necessary, taking into account the
complexity and number of requests and we inform you of such extension within the initial
45 days response period, together with the reason for the extension.
If we decline to take action on your request, we shall so inform you without undue delay,
within 45 days of receipt of your request. The notification will include a justification
for declining to take action and instructions on how you may appeal. Within 60 days of
our receipt of your appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons for the
decisions. If the appeal is denied, you may submit a complaint to the Connecticut
Attorney General at link: https://www.dir.ct.gov/ag/complaint/ or (860) 808-5318.
We shall provide information in response to your request free of charge, up to twice
annually, unless requests are manifestly unfounded, excessive or repetitive. If we are
unable to authenticate your request using commercially reasonable efforts, we may
request additional information reasonably necessary to authenticate you and your
request. If we cannot authenticate you and your request, we will not be able to grant
your request.
E. ADDITIONAL NOTICE TO UTAH RESIDENTS (effective January
2024)
Under the Utah Consumer Privacy Act (the “UCPA”) if you are a resident
of Utah, acting in an individual or household context (and not in a
commercial or employment context) your rights with respect to your personal data are
described below. “Personal Data" refers that is linked or reasonably
linkable to an identifiable individual, and does not include de-identified data and
publicly available data.
The categories of personal data processed, purpose of processing, are detailed in Section
3 “DATA COLLECTED BY dragas.co & PURPOSE OF USE”.
Disclosure of sale of data or targeted advertising
are detailed in Section 6 “YOUR RIGHTS RELATED TO YOUR PERSONAL DATA & OPT-OUT”
above, and in the e-mail DSR Form.
Further, the table above under “ADDITIONAL NOTICE TO COLORADO RESIDENTS” details the
rights you have under CDPA and how you may exercise your rights.
F. NOTICE TO NEVADA RESIDENTS
Nevada law allows Nevada residents to opt out of the sale of certain types of personal
information. Subject to several exceptions, Nevada law defines “sale” to mean the
exchange of certain types of personal information for monetary consideration to another
person. We currently do not sell personal information as defined in the Nevada law.
However, if you are a Nevada resident, you still may submit a verified request to opt
out of sales and will record your instructions and incorporate them in the future if our
policy changes. You may send opt-out requests to contact@dragas.co.
