Privacy Policy

Last updated on May 24, 2018

This Privacy Policy sets out how we, GroupGifting.com, Inc. d/b/a eGifter (eGifter, us, our or we), collect, transfer, store and use information about you when you use or interact with our any of our websites or mobile apps and where we otherwise obtain or collect information about you. We take our obligations regarding privacy seriously and want to ensure that you are fully informed about the care and use of the information you are providing to us.

We may collect information from you, including your name, postal address, e-mail address, telephone number, cell phone number, IP address, date of birth, age, gender, payment information, social media account information, referring site, and other technical information.

All of eGifter’s websites and mobile apps, including all products and services offered through them, are collectively referred to in this Privacy Policy as the Services.

Contents

  1. Important information about eGifter and our offerings
  2. Information we collect when you visit our websites or mobile apps
  3. Information we collect when you contact us
  4. Information we collect when you interact with our Services
  5. Information we collect when you place an order through our Services
  6. Information collected or obtained from third parties
  7. Our use of automated decision-making and profiling
  8. Disclosure and additional uses of your information
  9. How long we retain your information
  10. How we secure your information
  11. Your rights in relation to your information
  12. Sensitive Personal Information
  13. Changes to our Privacy Policy
  14. Children's Privacy
  15. Your California privacy rights

1. Important information about eGifter and our offerings

The data controller in respect of our services is eGifter, located in the United States. You can contact the data controller by sending an email to privacy@egifter.com.

BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, STORAGE AND USE OF YOUR PERSONAL INFORMATION FOR PROCESSING IN THE UNITED STATES.

If you have any questions about this Privacy Policy, please contact the data controller.

2. Information we collect when you visit our websites or mobile apps

We collect and use information from users of our Services in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use cloud-based providers to host the servers and provide infrastructure components and software used by our Services. Our servers automatically log the IP address you use to access our Services as well as other information about your visit such as the pages accessed, information or products requested, the date and time of the request, the source of your access to our Services (e.g. the website URL (link) which referred you to our Services), and other information regarding your visit and interactions with our Services.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and the Services remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make any attempt to identify you from the information collected via server logs.

Use of website server log information to analyse website use and improve our website

We use the information collected by our server logs to analyse how our users interact with our Services and their features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our Services. For example, we use the information gathered to change the information, content and structure of our Services and individual website pages based according to what users are engaging most with and the duration of time spent on particular areas of our Services.

Cookies and Tracking Technologies

Use of cookies and tracking technologies our Services

Cookies are data files which are sent from a website to a browser to record information about users for various purposes. We may use session cookies, which terminate when a user closes their browser, and/or persistent cookies, which remain on the user's computer until manually deleted.

We use cookies and similar technologies, including essential, functional, analytical and targeting cookies, tags, single-pixel GIF image files (also called web beacons), tracking pixels, local objects and similar information gathering technologies. We use cookies to save you time while using the Services, tell us who you are, track and target your interests to provide a better user experience.

Our Services may also use cookies and tracking technology to collect your information as you browse, such as your browser type and version, device type, device operating system, information accessed, pages viewed, the Internet Protocol (IP) address by your computing device and other relevant statistics. Such information is sometimes referred to as web analytics.

You can reject some or all of the cookies we use on or via our Services by changing your browser settings or by using our cookie control tool, but doing so can impair your ability to use our Services or some or all of its features.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) and other related technologies in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.

3. Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website or one of our other email addresses, we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Contact and/or support form

When you contact us using our contact or support form, we may collect your information, such as your name, email address, and phone number. We also collect any other information you provide to us when you complete the form.

If you do not provide the mandatory information required by our forms, you will not be able to submit the contact or support form and we will not receive your request.

Phone

When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us. While we do not record phone calls as a normal course of business, we may record certain calls for quality assurance or training purposes and notify you of such. You may also leave a voicemail message with your information that is digitally recorded and stored in our phone and/or support systems. If the voicemail is received as a result of a support request, the voicemail is saved with that request.

Mail

If you contact us by mail, we will collect any information you provide to us in any postal communications you send us.

4. Information we collect when you interact with our Services

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E-Newsletter

When you sign up for our e-newsletter or opt to receive news, offers or other notices from us by entering your name and email address and clicking to subscribe or ticking a box at checkout indicating that you would like to receive our e-newsletter or other notices, we collect your name, email address and other information that you provide at the time of sign up.

Registering for our Services

When you register and create an account on our Services, we collect the following information: name, email address and any other information you provide to us when you complete the registration form, including any optional information, such as phone number or mailing address.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account for our services.

5. Information we collect when you place an order through our Services

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect, based upon your selected payment method, your name, name on credit card, credit card number, expiration date, CVV, billing address, phone number, email address and recipient details (if sending a gift).

If you do not provide this information, you will not be able to purchase goods or services from us through our Services. We need the mandatory information collected by our checkout form to establish your identity and to contact you to fulfil our obligations, including sending you receipts and order confirmations.

Optional information

We also collect optional information from you, such as your mobile phone number or Facebook address. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.

Processing your payment

After you place an order through our Services, you will need to make payment for the goods or services you have ordered. In order to process your payment, we use third party payment processors. Your payment will be processed by any one of a number of different processors, depending on the payment method selected by you at checkout or our selected payment processor for your order.

Marketing communications

At checkout you will have the option of receiving marketing communications from us.

You can opt in to receiving marketing communications from us in relation to our goods and services by email by indicating that you would like to receive such communications during your checkout process.

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

6. Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We receive information about you from third parties. The third parties from which we receive information about you will generally include fraud detection or management services. This information is required in order for us to provide the Services to you, including your ability to complete an order using our Services.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

7. Our use of automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement. We use automated decision making based on your information, which may be provided by you or collected by us from third parties such as fraud prevention agencies. Automated decisions are made as part of fraud prevention efforts and anti-money laundering checks. We do not consider that this has any legal effect on you or similarly significantly affects you.

8. Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who may process your information for us on our behalf. These include the following:

  • Payment processors
  • Email providers
  • Telephone service providers
  • IT service providers
  • Cloud service providers
  • Fraud detection and analytics providers
  • Security monitoring and analysis providers

Our third-party service providers are located in the United States.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email to privacy@egifter.com and we will provide you with such information where you have a legitimate reason for requesting it.

Disclosure of your information to other third parties

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers.

Further information on each of these third parties is set out below.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors and lawyers. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Business partners

Business partners are businesses we work with which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide in connection with our own services.

Independent contractors

We use independent contractors in our business. Your information will be shared with independent contractors subject to confidentiality requirements and only where it is necessary for them to perform the function we have hired them perform in relation to our business.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

We do not display the identities of the third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly by email at privacy@egifter.com and we will provide you with such information where you have a legitimate reason for requesting it.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or in connection with suspected or potential money laundering matters.

9. How long we retain your information

We will retain your information for as long as your account is active, your information is needed to provide you services or fulfill your orders, or as required to fulfill our legal obligations. If you wish to delete your account or request that we no longer use your information to provide you services, contact us at privacy@egifter.com. We will respond to your request within 30 days provided that we can verify the request and your authority to make such a request. We will retain and use your information as necessary to fulfill our obligations and agreements, resolve disputes and comply with our legal obligations.

10. How we secure your information

We take appropriate technical and organizational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our Services and any payment transactions you make on or via our Services; and
  • only transferring your information via closed system or encrypted data transfers
Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

11. Your rights in relation to your information

Under certain circumstances and subject to limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to privacy@egifter.com:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information, where we are required to erase, based upon your verified request, your personal information to comply with local law;
  • to request that we restrict our use of your information;
  • to receive, where it is possible, information which you have provided to us in a structured, commonly used and machine-readable format and the right to have that information transferred to another data controller (including a third-party data controller);
  • to object to the processing of your information for certain purposes where you feel it impacts your fundamental rights and freedoms, including for direct marketing purposes. As it pertains to direct marketing, you may opt out by clicking an unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link; and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

12. Sensitive Personal Information

"Sensitive personal information" is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

13. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email or by posting a notice on our website.

We will provide information about the change in question and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

14. Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The Services are not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to privacy@egifter.com.

15. Your California Privacy Rights

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user.

Certain technologies that we deploy respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding eGifter's disclosure of personal information to third parties for such third parties' direct marketing purposes. To make such a request, please write to eGifter, Inc. 315 Main Street 2nd Floor, Huntington, NY 11743.

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