Last updated: July 27, 2021
Interpretation and Definitions
The words in which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
- You mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
- Company (referred to as either "the Company," "We," "Us," or "Our" in this Agreement) refers to Index Web Solutions Ltd, H-1138 Budapest, Váci út 140. - EU. Contact may be found here.
- For the GDPR, the Company is the Data Controller.
- Affiliate means an entity controlled by or under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors other managing authority.
- Account means a unique account created for you to access our Service or parts of our Service.
- Website refers to 10 minute emails, accessible from https://www.10minuteemails.com.
- Service refers to the Website.
- Country refers to Hungary, EU.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used.
- For the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an account to use the Service.
- Personal Data is any information that relates to an identified or identifiable individual.
- For GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
- For the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Cookies are small files placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Usage Data refers to data collected automatically, either generated by the service or the Service infrastructure itself (for example, the duration of a page visit).
- For the GDPR (General Data Protection Regulation), Data Controller refers to the Company as the legal person who, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
- Do Not Track (DNT) is a concept promoted by US regulatory authorities, particularly the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
- Business, for the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
- For the CCPA (California Consumer Privacy Act), a consumer means a natural person who is a California resident. As defined in the law, a resident includes (1) every individual in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA, which is outside the USA for a temporary or transitory purpose.
- Sale, for the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to:
- Usage Data
Usage Data has collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or access the Service by or through a mobile device.
Tracking Technologies and Cookies
You can instruct Your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.
We use both sessions, and persistent cookies for the purposes set out below:
- Necessary / Essential Cookies
- Type: Session Cookies
- Administered by: Us
- Purpose: These cookies are essential to provide You with services available through the Website and enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services you have asked for cannot be provided, and We only use these Cookies to offer you those services.
- Cookies Policy / Notice Acceptance Cookies
- Type: Persistent Cookies
- Administered by: Us
- Functionality Cookies
- Type: Persistent Cookies
- Administered by: Us
- Purpose: These cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and avoid re-enter your preferences every time. You use the Website.
- Tracking and Performance Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These cookies track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the data collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to test new advertisements, pages, features, or the website's new functionality to see how our users react to them.
- Targeting and Advertising Cookies
- Type: Persistent Cookies
- Administered by: Third-Parties
- Purpose: These cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest. These Cookies use information about your browsing history to group You with other users who have similar interests. Based on that information, and with Our permission, third-party advertisers can place cookies to enable them to show adverts that we think will be relevant to your interests while You are on third-party websites.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including monitoring the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different Services available to You as a registered user.
- For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers, and general information about other goods, services, and events that we offer similar to those you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
- For Business transfers: We may share or transfer Your personal 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.
- With Business Partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
- When you share personal information or otherwise interact in public areas with other users, all users may view such information and may be publicly distributed outside. Suppose You interact with other users or register through a Third-Party Social Media Service. In that case, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will view descriptions of Your activity, communicate with You and view Your profile.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter time, except when this data is used to strengthen the security or improve our Service's functionality. We are legally obligated to retain this data for more extended periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Other legal requirements
The Company may disclose Your Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our Service.
- Google Analytics
- Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
We may use Service providers to show advertisements to You to help support and maintain Our Service.
- Google AdSense & DoubleClick Cookie
- You may opt-out of using the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary to protect Your vital interests or those of another natural person.
- Public interests: Processing Personal Data is related to a task carried out in the public interest or the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the legitimate interests pursued by the Company.
In any case, the Company will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please Contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information we hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We rely on legitimate interest as the legal basis for Our processing, and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason to continue processing it.
- Request the transfer of Your Personal Data. We will provide you or a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for Us to use or used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You cancel Your consent, We may not provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If you request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Your Rights under the CCPA
- The right to notice. You must be appropriately notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits You to request and obtain the Company information regarding the disclosure of Your Data collected in the past 12 months by the Company or its subsidiaries to a third party for the third party's direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.
- The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected.
- The sources from which the personal data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the deletion of Your Data collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
To exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us or visit our "Do Not Sell My Personal Information" section or web page.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal data as defined by the CCPA law.
Suppose you wish to opt-out of using your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law. In that case, you may do so by following the instructions below.
Please note that any opt-out is specific to the browser You use. You may need to opt-out of every browser that you use.
You can opt-out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- From Our "Cookie Consent" notice banner
- Or from Our "CCPA Opt-out" notice banner
- Or from Our "Do Not Sell My Personal Information" notice banner
- Or from Our "Do Not Sell My Personal Information" link
The opt-out will place a cookie on Your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.
Your mobile device may give you the ability to opt-out of the use of information about the apps you use to serve you ads that are targeted to your interests:
- "Opt-out of Interest-Based Ads" or "Opt-out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices.
You can also stop collecting location information from Your mobile device by changing the preferences on your mobile device.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of Your browsing activities. If you visit such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and aware that Your child has provided Us with Personal Data, please Contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verifying parental consent, we remove that information from Our servers.
We also may limit how We collect, use, and store some of the users' information between 13 and 18 years old. In some cases, this means We will be unable to provide specific service functionality to these users.
Suppose We need to rely on consent as a legal basis for processing Your information and Your country requires permission from a parent. In that case, We may require Your parent's consent before collecting and using that information.
Links to Other Websites
We have no control over and assume no responsibility for any third-party sites or services' content, privacy policies, or practices.
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