Last updated: January 24th, 2023
1. Automatic Collection of Personal Information
2. Optional Personal Information
You may generally access and use the Website and Services without telling us who you are or revealing Personal Information by which someone could identify you. However, to use specific features, you may be asked to provide certain Personal Information such as your name and e-mail address. You may choose not to provide this information, but please note that without this information, we may be unable to provide the full range of our Services and the best user experience. When you do knowingly provide Personal Information to us, such as when you create a Madgicx Services account or complete online forms on our Website, we receive and store such information. We may also collect other Personal Information about you from third-party sources, such as public databases and our joint marketing partners. If you are uncertain about which Personal Information is optional or mandatory to use the Website and Services, please contact us at firstname.lastname@example.org.
3. Use and Processing of Information
In order to make the Website and Services fully available to you, we may need to collect and use certain Personal Information. If you do not provide the information, we may not be able to provide you with all requested products or services. Any of the information we collect from you may be used to help us run and operate the Website and Services, including to measure interest and engagement, to improve, troubleshoot or develop the Services, to ensure quality control and safety, to carry out audits, to communicate with you about your account, your activities on our Services and policy changes, to prevent or prosecute prohibited or illegal activities, to enforce our agreements and to comply with our legal obligations.
How we process Personal Information depends on (a) how you interact with the Website and Services, (b) where you are located in the world, and (c) whether or not one of the following applies:
Note that under some laws, we may be allowed to process information until you object (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
We may use Personal Information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
4. Managing Information
You may delete certain Personal Information that we have about you. The Personal Information that you may delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records, solely for the period of time necessary to comply with our obligations to our affiliates and partners, and for the purposes described herein. If you would like to delete your Personal Information or permanently delete your Madgicx account, you may do so on the settings page of your account on the Website.
5. Disclosure of Information
To maintain the highest level of privacy and protect your Personal Information to the fullest extent, we do not share your Personal Information with anyone or for any reason.
6. Retention of Information
7. Transfer of Information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including but not limited to, the United States. As explained in further detail herein, we endeavor to safeguard your information consistent with the requirements of applicable laws. You are entitled to learn about the legal basis of information transfers to a country outside the European Economic Area (“EEA”) or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If you have questions about any such transfers, please contact us by e-mail at email@example.com.
8. Data Protection Rights Under GDPR
Under GDPR, the main legal bases that we rely on to process Personal Data collected by the Services include the following:
As noted herein, we may share your Personal Data with trusted third parties where we have retained them to provide services that you or our clients have requested, and to perform maintenance or respond to technical issues involving the Services. You may request a list of sub-processors that we currently engage, by emailing us at firstname.lastname@example.org. Where we disclose Personal Data to third parties, we require minimum standards of confidentiality and data protection.
To the extent that your Personal Data is transferred outside of, or accessed from outside of, the EEA, we will ensure that approved safeguards are in place to comply with GDPR, such as the European Commission's approved standard contractual clauses. In limited circumstances, transfers of Personal Data may be based on context specific derogations which permit transfers in the absence of safeguards, such as where a transfer is necessary for the establishment, exercise or defense of legal claims.
You have the following rights in relation to Personal Data that we hold about you, which rights you may exercise by emailing us at email@example.com. We will require evidence of your identity before being able to act upon your request.
If you are located in the EEA or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe that our processing of your Personal Data violates applicable law.
9. California Privacy Rights
This section only applies to our processing of Personal Information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) or the California Privacy Rights Act of 2020 (“CPRA”). California residents have the right to know what categories of Personal information we have collected about them, whether we disclosed that Personal Information for a business purpose (such as to an affiliate, service provider or business partner) in the past 12 months, and how long we retain the Personal Information. California residents can find this information below:
For purposes of California law, we do not “sell” Personal Information except as may be disclosed herein (“sell” is broadly defined under California law), nor do we have actual knowledge of any “sale” of Personal Information of minors under 16 years of age.
For purposes of California law, we do not “share” Personal Information (in other words, we do not share Personal Information with a third party for cross-context behavior advertising or interest-based advertising, whether or not for payment).
In addition to the GDPR rights above, if you are a California resident, you (and in some cases, you authorized agent) may contact us to request deletion of your Personal Information. You may also contact us to request correction of your personal data.
To the extent that we may use any data profiling technology (automated decision-making technology that we may use to profile your habits, interests, or economic activity, you have the right to learn about that technology, and opt-out of us using your information for profiling you across the following categories: behavior, economic situation, health, interests, location or movements, performance at work, personal preferences, or reliability.
To the extent that we may process any Sensitive Personal Information under the CPRA, you may contact us to opt out of us using this information for anything other than supplying goods or services that you request.
California residents have the right not to receive discriminatory treatment by Madgicx for the exercise of their rights conferred by the CCPA or CPRA.
10. How to Exercise Your Rights
Any requests to exercise your rights can be directed through the Website as indicated, or you may contact us by e-mail at firstname.lastname@example.org or as otherwise set forth below. Your request must include sufficient details to allow us to properly understand the request and respond to it. And before we respond, we may ask you to verify your identity with sufficient information. We cannot respond or provide Personal Information unless we first verify your identity or authority to make such a request, and confirm that the Personal Information relates to you.
11. Privacy of Children
The Website and Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from children. If you learn that your child has provided Personal Information to us without your consent, you may contact us by e-mail at email@example.com or as otherwise set forth below. If we learn that we have collected a child’s Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
12. Links to Other Resources
The Website and Services may contain links to other websites/applications, and other websites/applications may reference or link to us. We do not control these third-party services. We encourage you to carefully read the privacy policies and other applicable terms and policies of each third-party website and application with which they interact. Subject to the terms herein, we do not endorse, screen or approve, and we are not responsible for, the privacy practices or content of such other websites or applications. You provide Personal Information to third party websites or applications at your own risk.
13. Information Security
We secure Personal Information that you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure. However, no data transmission over the Internet or wireless network can be fully guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge: (a) the Internet has some security and privacy limitations that are beyond our control; (b) we cannot guarantee the security, integrity, and privacy of information and data exchanged between you and the Website and Services; and (c) despite best efforts, a third party may view or tamper with any such information and data while in transit.
14. Data Breach
If we become aware that the security of the Website and Services has been compromised or that users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. If there is a data breach, we will make reasonable efforts to notify affected individuals, if we believe that there is a reasonable risk of harm to the user as a result of the breach or if the notice is otherwise required by law. When we do, we will post a notice on the Website or Services, or we will send you an email.
15. Changes and Amendments
16. Contact Us
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