April, 14st 2020
Giveaway Ninja (“Giveaway Ninja”, or “we”, or “our”, or “us”) understands that your privacy is important to you and that you care about how your information is used and shared online.
We respect and value the privacy of everyone who visits Our Site and uses our Giveaway App and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site and Our Giveaway App.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site and Giveaway App;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
means this website, www.GiveawayNinja.io
means website owner’s, merchants and administrators that purchased and/or added our Giveaway App to their website(s) to collect e-mails and deliver discount coupons to their Users.
Anybody accessing Our Site or the Giveaway App provided by Us
means the giveaway management features provided by our software
means GiveawayNinja by Andrea De Santis
2. Information About Us
2.1 - Our Site and Giveaway App is operated by Giveaway Ninja
3. Scope – What Does This Policy Cover?
It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users).
We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. What Data Do We Collect?
Some data will be collected automatically by Our Site and our Giveaway App, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account.
Depending upon your use of Our Site, We may collect some or all of the following data:
- 4.1 - your account registration data (username, email, password);
- 4.2 - business/company name and billing information;
- 4.3 - IP address and location information as state and city (automatic)
- 4.4 - web browser type and version (automatic);
- 4.5 - operating system (automatic);
- 4.6 - referring site and UTM fields
- 4.7 - sale value
5. How Do We Use Your Data?
5.1 - All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 - We use your data to provide our Giveaway App to you. This includes:
- 5.2.1 - Providing and managing your Account;
- 5.2.2 - Providing and managing your access to Our Site and Giveaway App;
- 5.2.3 - Personalising and tailoring your experience on Our Site and Giveaway App;
- 5.2.4 - Supplying Our Giveaway App services to Customers and his Users
- 5.2.5 - Responding to communications from you;
- 5.2.6 - Troubleshooting, detecting and protecting against error, fraud, or other criminal activity;
- 5.2.7 - Supplying you with newsletters, alerts etc. that you have subscribed to; you may unsubscribe or opt-out at any time by opt-out link provided on communications or by contacting us at firstname.lastname@example.org
- 5.2.8 - Marketing retargeting campaigns;
5.2.9 - Compute aggregated metrics (such as pages views and total number of visitors) for statistical analysis including without limitation determining trends and patterns about usage and demographics for the purpose of improving the Services, by taking reasonable measures to anonymize private information whenever possible
5.3 - In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
5.4 - With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 - Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.6 - Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child
6. How and Where Do We Store Your Data?
6.1 - We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
In any event, We will conduct an annual review to ascertain whether we need to keep your data.
Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy:
- Collected e-mails and stats are stored for a maximum of 12 months
- Inactive accounts are removed after a maximum of 12 months
- Billing information and invoices as long as required to fulfill Our tax obligations
6.2 - Data is stored on AWS Servers located in US west zones.
6.3 - Information you provide to us is stored on our secure servers. Encrypted connections using SSL technology are used whenever applicable.
6.4 We take security very seriously, and ‘privacy by design’ is baked into our engineering and product development principles but as with any online service, despite our use of leading security tools and techniques, the personal data we hold about you can never be 100% immune from unauthorised access.
7. Do We Share Your Data?
7.1 - We may contract with third parties to supply our services to you on Our behalf. These may include payment processing, cloud infrastructures, database-as-a-service, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.2 - We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 - In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 - In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
9.1 - The platform provides tools for Customers and their Users to manage their Account (remove messages, change password, edit username and location). You may also send a request at email@example.com to correct, amend, delete and obtain a copy of your personal data.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 - You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10.3 - You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org.
By using Our Site and/or Giveaway App you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us.
1. We use both session and persistent cookies on Our Site
__RequestVerificationToken - used to improve security
countryCode and cookieconsent_status - used to handle the cookie consent status
2. The names of the cookies that we use on the Giveaway App, and the purposes for which they are used, are set out below:
- giveawayninja_at- security access token
giveawayninja_initial_page - first page used by the user
giveawayninja-referrer - referrer site
giveawayninja_refid - referral id
giveawayninja_user_country - user country
giveawayninja_tz - user timezone
Third party cookies
- We use Google Analytics, Inspectlet and The Facebook Pixel to analyse anonymously the use of our Site and App.
- Our analytics service provider generates statistical and other information about website and dashboard usage required to operate our business.
The information generated relating to our website is used to create reports about the use of our website.
Our analytics service provider's privacy policies are available at:
- Our Site also uses third party cookies.
- We publish cookies from Hotjar which are used for analytics and tracking what users do on our website.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling
14. Contacting Us
We recommend that you check this page regularly to keep up-to-date.