Privacy

Privacy

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Data protection provisions

This Policy explains how personal information that is collected, used and disclosed by Custom Paywall  Solution LLC. Custom Paywall Solution LLC attaches extreme value to the protection of your personal data. We create, process and use your personal data exclusively in accordance with the principles referred to below and obeying the applicable data protection laws.

We comply with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. To learn more about the Safe Harbor program, please visit their website.

This Policy does not apply to websites, applications, or services that display or link to different privacy statements. This Policy also does not apply to information we collect on behalf of our customers through our analytics platform.

Your personal data

Personal data includes all information that relates to a particular or identifiable person:

• This includes among other things your name, your telephone number as well as your postal address and email address required for us to transact with you; and
• Technical information (Browser type, computer operating system and the address of a referring website as well as the path you take through our web pages during your visits)

Your data is created for the process referred to below.

Custom Paywall Solution creates processes and uses your personal data only in connection with the organization and the management of a customer account; including the provision of the services offered in connection with the customer account.

We use your information as follows:

• Ensure that the contents of the websites are represented in the way that is most effective for you and your computer.
• Process your enrollments and inquiries.
• Provide you with information, products and services that you have either asked us to provide you with or in respect of which we believe that they might be of interest to you.
• Protect, investigate and deter against fraudulent, unauthorized or illegal activity.
• Link or combine it with other information we get from third parties, to help understand your needs and provide you with better service.
• Fulfill our obligations in connection with agreements that have been created between you and us.
• Draw your attention to changes in our service provision portfolio, in so far as you have declared to agree to being contacted for such purposes.
• Advertise to you on 3rd party websites Protection of your data.

We also use this information to communicate with you through email correspondence. We reserve the right to contact you if necessary with specific information related to your account.

Your Account

On our application (Excalibur and/or others) you might be offered an opportunity to create a personal profile account for your convenience. You can use your personal profile account to store your personal information and can use that information to facilitate shopping in the Online Store easily. In addition, Excalibur offers you a particular function, like for instance an overview of your purchasing history.

The personal profile account is managed by Excalibur. To set up your personal customer account Excalibur needs your First Name and Last Name, your email address as well as a password chosen by you. The email address you give us will at the same time serve as log-in ID for personal profile account. Here your information could be quickly updated by you at any time.

The use of third-party websites and service providers

For the dispatch of the quality service provided to you, Custom Paywall Solution makes your personal data available to other service providers, who process these data for the order of our application and are in compliance with these data protection provisions as well as the necessary security measures.

Newsletter, subscription, customer surveys

At regular intervals Custom Paywall Solution sends newsletters to registered interested parties. In so far as you have registered for a Custom Paywall Solution Newsletter, we create and process your personal data exclusively for the dispatch of the newsletter concerned. Your data will be deleted immediately when you terminate the newsletter subscription concerned. You can at any time cancel your subscription via the link contained in the newsletter.

Your personal information is only shared and made available to:

• Organization – We share your personal information with the organization with whom you have acquired a subscription through our service. Your data is a co-asset of the Organization and Custom Paywall Solution LLC as the partnership agreement established between us. It is advised to also read the privacy policy of the organization to whom you have opened a subscription.
• Email Service Providers – Email address and name are shared with email service providers that send emails and correspondences concerning your subscription. These third-parties are only authorized to use your information for the process of your payment.
• Payment Service Provider – Your payment information as previously stated is shared with third-party providers to process your transaction. These third-parties are only authorized to use your information for the process of your payment.

Your personal information is not shared and/or distributed with any other parties for any other purpose than the stated above.

Exception clause

We may have to disclose your information:

• As required by law; compliance with a subpoena or other legal actions;
• When the disclosure of such information is for the protection of our rights and the rights of our partners as well as others, the respond to governmental requests, the investigation of fraudulent activities;
• The event of a merger or acquisition of our company by another company. Your personal information is considered as part of the many assets transferable during that acquisition or merger. You will be off course notified by email of any changes in ownership and/or control of your personal data.

Contacting Us and Dispute Resolution

In compliance with the US-EU and US-Swiss Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact us. For complaints that cannot be resolved between us and the individual concerned, we agree to participate in the Better Business Bureau EU Safe Harbor independent dispute resolution program.

Individuals who submit a complaint or concern to us but do not receive acknowledgement from us or who think the complaint or concern has not been satisfactorily addressed should then contact to the Better Business Bureau to participate in its dispute resolution procedure. In addition, the United States Federal Trade Commission is the statutory body that has jurisdiction to hear any claims against us regarding possible unfair or deceptive practices and violations of laws or regulations governing privacy.

Information we share

We do not share your personal information with third parties. Other than user browsers related information such as cookie data.

Our privacy policy does not cover any third party services. To learn about those third parties’ privacy practices, please visit their policies.

Governing Law

This privacy policy will be governed by the laws of the United States. In the event of any legal action, the user hereby consents to the jurisdiction of the State of New York courts and waives the defense of lack of personal jurisdiction by such courts.

Amendments

Custom Paywall Solution reserves the right to amend these data protection provisions at any time.

Contact

Questions, remarks and suggestions in respect of these data protection guidelines are always welcome and should be addressed to info@customportalsolution.com