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Privacy Policy with GDPR Addendum

 

This website and service entitled MarcRothken.com is owned by MashLaunch Incorporated (“WD”) and it values its visitors, members, and customers, and we are glad to have you visit us. We are committed not only to making great App, services, and products, but also to respecting the privacy rights of those who visit and use our website. This Privacy Policy provides a guide as to how we collect, store and use the information that you provide to us online, including how we may share information, and it will also let you know how you can change the way we may collect personal information from you. We also discuss notices of changes that may be made to this Privacy Policy. This Privacy Policy applies to any website owned or controlled by WD, including applications, and references to a “Site” are applicable to all such websites, services, and Apps, including www.WebsiteDiligence.com.

 

BY USING ANY OF OUR SITES, APPS, PRODUCTS, SOFTWARE, OR SERVICES, YOU AGREE TO ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE OUR SITES.

 

What information do we collect and how is it used?

 

The type of information that WD collects will vary depending on the activity and may include what is known as “personally identifiable information” or “personal information” including, for example, your first and last name, e-mail address, account information for certain third party sites or networks such as Facebook, Google, or Twitter, phone numbers (including cell phone numbers), home address, business address, business information, website domain names, and zip code. Personally identifiable information can be accessed in order to directly contact you and to carry out our services. We also collect additional types of personally identifiable information (e.g., credit card and billing and shipping information, including physical addresses and phone numbers) when someone purchases products and offerings at our Sites. Such purchases are governed by our Terms of Use. The Site(s) Terms of Use are incorporated herein by reference. We may share your personal information with third parties in order to provide our goods and services or to have them assist with fulfillment of the same, including, for example, shipping and credit card processing, and companies that assist us with e-mailings, but such third parties agree to maintain the security of your personal information in a manner consistent with this Privacy Policy. In addition, we may collect demographic information such as: gender: information about your computer, hardware, software and/or platform; Internet IP address and connection; information about online activity such as website usage and time spent on the WD website; and, other data that you may provide.

 

Electronic Newsletter and Subscription to other Updates about WD

 

WD may offer users the opportunity to sign up to receive the WD monthly newsletter as well as news, service, app, marketing and press updates related to WD (collectively, “Updates”). WD does not guarantee or promise the frequency in which Updates may be sent and reserves the right to discontinue sending Updates at any time. To sign up for Updates, you must be eligible to register with WD and provide your e-mail address, first name, create a password and, at your option, a screen name. Information collected for WD Updates may be transferred, disclosed, or shared with third parties who may be engaged by us specifically to handle the preparation and delivery of the Updates and perform other related technical and processing functions. These third parties may not use it for other purposes and have agreed to maintain the confidentiality of such information. Sign-up for Updates is always optional, and users who no longer wish to receive our Updates and communications may opt-out of receiving these communications by clicking on the “unsubscribe” link in the email or email us at optout@WD.com. or you may contact us by post at WD, Inc., Attn: Customer Service, 3 Hamilton Landing, Suite 280, Novato, CA  94949 to opt-out.

 

Forums

 

At your own discretion, and once you meet certain eligibility requirements, you may choose to post or upload additional facts and material about yourself, including a biography, birth date (with the year being optional) a profile picture, your location, your interests or your occupation and we may use the same to provide our services. Please note that information, additional facts or any other materials that you post anywhere on the public portion of our Sites, including any information or materials that you choose to make public on the Forums, will be available for any user to read, and are therefore no longer private. A third party may disclose any information or materials you choose to post. Also, information and material that you post could be used by someone to send you unsolicited messages. Once posted, you cannot change or remove any public postings made in our Forums or other message areas (although WD reserves the right to remove any such public postings in its sole discretion), and we are not responsible for the personally identifiable information or material you choose to submit. We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with our Terms of Use.

 

Policy Against Unsolicited Submissions

 

As further described in our Terms of Use, please note that WD has a policy against accepting unsolicited material, so we ask that you do not submit any unsolicited or unique creative ideas, drawings or other materials to WD directly or otherwise in connection with any posts you make to the Forums or in connection with additional facts or material you may provide in any posting on any of our Sites.

 

Third Party Links

 

To provide relevant information not found on our Sites, WD may provide links from our Sites to third party websites. We encourage our users to read third party websites’ privacy policies before submitting personal information. Correspondence With WD If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our Sites, we may collect such information into a file which is only accessed by authorized personnel. We may also collect other users’ comments about you in our complaints department.

 

Tracking Information of our Users

 

In the course of using our Sites, we automatically track certain information such as your IP addresses and email addresses. We may tie your IP address to your personally identifiable information. We automatically track information through the use of a “cookie.” A “cookie” is a piece of data stored on the user’s computer tied to information about the user. WD uses cookies to collect non-personally identifiable information through the Sites. Some of our business partners use cookies on our Sites (for example, advertisers). We may use third-party advertising companies to serve ads on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. However, we have no access to or control over these cookies, once we have given permission for third parties set cookies for advertising.Information we collect through cookies and other information from our log files about your activity on the Sites is used to help resolve technical problems or issues and may also assist in making your visit more enjoyable (for example, using a cookie will allow you to use certain features on our Sites without having to log in each time you visit). WD also collects IP addresses (an IP address is the string of numbers that identifies each sender or receiver of information that is sent across the Internet), for the purposes of system administration, to report aggregate information internally and to some of our business partners and advertisers and to audit the use of our Sites. When visitors request pages on one of our Sites, our servers log the visitors’ IP addresses. We collect log files that record activity on our Sites and gather statistics about visitor’s time and activity on the Sites. The statistics are generated anonymously, and they help us in connection with marketing and demographic studies as we enhance our Sites. WD does not normally link IP addresses to anything personally identifiable, which means that a user’s session will be logged, but the user remains anonymous to us. WD can and will use IP addresses to identify a user when we feel it is necessary to enforce compliance with our Terms of Use, to protect our services, Sites or a person or entity.If we are going to use your personally identifiable information in a manner different from that stated at the time of collection, we will post a notice prominently on our Sites. You will have a choice as to whether or not we use your information in this different manner. In some cases where we post the notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices. Your use of Other Users’ Information You may not use other Site users’ information for commercial purposes, to spam, to harass, or to make unlawful threats. WD reserves the right to terminate those who misuse other users’ information or who otherwise violate the WD Terms of Use.

 

Control of Your Password

 

You may not disclose your password to any third parties or share it with any third parties. If, despite the foregoing, you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. Reviewing, Changing or Deleting Your Personally Identifiable Information Once you register, you may be able to review and change much of your personally identifiable information at WD including:Your email address, password and subscription settings. Please promptly update your information if it changes by logging in to your account if applicable and following the screen prompts. We strongly urge you to periodically change your password to help reduce the risk of unauthorized access to your account information. We will retain in our files information, including personal information, you have requested to remove in some circumstances, such as to resolve disputes, troubleshoot problems, comply with contest rules and law, comply with industry rules and regulations, enhance security, reduce fraud, comply with federal and state law and to enforce our Terms of Use. This Privacy Policy covers only information that is collected through our Sites, and does not cover information that may be collected through software downloaded from the Sites. Our Sites may contain links to other websites. Please be aware that WD is not responsible for the privacy practices of such other websites. We encourage our users to be aware when they leave our Site(s) to read the privacy statements of each and every website that collects personally identifiable information.  

 

Wish to Contact Us? If you have any questions regarding our Privacy Policy, please contact us at: Privacy Policy Officer MashLaunch Incorporated 3 Hamilton Landing, Suite 280 Novato, CA  94949 or e-mail us at:   info@mashlaunch.com

 

Special Note to Parents and Guardians Anyone using the Internet should ensure that their privacy is being protected. This is especially true for kids under the age of 13 (defined herein as a “child” or, if the reference is to more than on child, then we will refer to “children”). WD is committed to complying fully with the Children’s Online Privacy Protection Act of 1998. We ask parents and guardians of children to discuss what information should be released on the Internet, especially personal information. WD does not condition a child’s participation in any of the activities available on our Sites on the disclosure of more information than is reasonably necessary to participate in the activity. WD does not knowing collect personally identifiable information from children under the age of 13. Note that WD may collect personally identifiable information from users of the Sites who are over 13 and under 18, and the collection and retention of this information is subject to the terms of this Privacy Policy. When a user in the 13-18 year old age category submits personally identifiable information, WD may, in accordance with applicable laws or regulations or at WD’s discretion, request a parent or guardian’s e-mail address to notify the parent or guardian of the activity of the user in this age category. In accordance with applicable rules and regulations, or at WD’s discretion, some areas of our Sites may not be accessible to anyone under the age of 18, regardless of whether a parent or guardian has provided consent.

 

Security

 

WD has security measures in place to protect and prevent the loss, misuse, and alteration of the information under our control. WD uses industry standard efforts to safeguard the confidentiality of your personal identifiable information such as firewalls. While “perfect security” does not exist on the Internet, our technical experts at WD work hard to ensure your secure use of our services.

 

Merger or Acquisition

 

While WD does not sell, rent, or otherwise disclose personal information collected from and about its users (including children under 13) to third parties except as specifically stated in this Privacy Policy, please note that in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, WD’s customer information (including your personally identifiable information) may be transferred to WD’s successors or assigns, if permitted by and done in accordance with applicable law.

 

Your California Privacy Rights

 

California Civil Code Section 1798.83 permits California residents to request from companies conducting business in California a list of third parties to which the company may have disclosed personally identifiable information for direct marketing purposes. WD does not share your personal information with third parties for their direct marketing purposes; however, if you believe WD may have shared such information, please feel free to contact WD at admin@mashlaunch.com or contact us at the physical address noted above (and provide contact information so that we may respond to you). WD will promptly respond to any requests in accordance with applicable law.

GDPR Addendum (May 25th, 2018)
 
EU Residents
 
If you are a resident of the European Union (“EU”) you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as further outlined below.
 
The purpose of this Privacy Addendum is to explain how our Site(s), Software, and company (MashLaunch, Inc.) ("we," "us," or "our"), secures, shares, and uses personal information that it collects and receives from you through its website, and marketing programs, affiliate programs, services, communications, mobile applications, ecommerce transactions, and other services (collectively, the “Service”).  If you have any questions or concerns regarding this Privacy Addendum or our practices, please contact us using the information provided below. 
 
We use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
 
Data Controller
We will be the controller of your Personal Data processed in connection with the Services. Upon request, we will provide you with information about whether we hold or process your personal information on behalf of third parties.
 
Data Processor 
We acknowledge, subject to the rest of this policy, that you have the right to access and change the personal information we collect and process as a data processor.  
 
Contact
If you have any questions or requests about this section please contact us at info@mashlaunch.com
 
Lawful basis of processing 
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others.
a. Insofar as you have given us your consent for the processing of your personal data, that consent is the legal basis for the processing (Art. 6 para. 1 letter a GDPR).
b. For the processing of personal data for the purposes of initiating or fulfilling a contract with you, Art. 6 para. 1 letter b GDPR is the legal basis.
c. Insofar as the processing of your personal data is necessary for the fulfillment of our legal obligations (e.g. for the retention of data), we are authorized to do so pursuant to Art. 6 para. 1 letter c GDPR.
d. In addition, we process personal data for the purposes of safeguarding our legitimate interests and the legitimate interests of third parties pursuant to Art. 6 para. 1 letter f GDPR. Maintaining the functionality of our IT systems, marketing our own and third-party products and services as well as documenting business contacts as required by law are such legitimate interests. Examples of these legitimate interests include:
Operation and improvement of our business, products and services
Marketing of our products and services
Provision of user support
Protection from fraud, legal, or security threats
Compliance with legal obligations, such as proof of licenses, authorization, and consent
Completion of corporate transactions
Compliance with KYC, age verification, and similar laws and regulations
Financial transactions record keeping and banking and credit card industry compliance Dispute resolution
 
Personal Data of Children
We do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself to us.
 
Rights You Have Regarding Your Personal Data
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email EMAIL ADDRESS. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes our rights or the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by updating any of the information contained in your user profile.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
 
Transfers of Personal Data
By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and may be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S.
 
Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf.
Analytics
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 own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
 
Amazon AWS

Amazon AWS is a cloud services and storage provider.

For more information on the privacy practices of Amazon AWS, please visit the Amazon AWS Privacy & Terms web page: 

https://aws.amazon.com/privacy/?nc1=f_pr


 
Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help in the secure handling of payment information.
 
Additional Disclosure of Data
Business Transaction: If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement: Under certain circumstances, we may be required to disclose your Personal 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).
 
Security of Data
The security of your 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.
 
Deletion of your personal data
We delete your personal data as soon as the purpose for which we have collected and processed the data ceases to apply. Beyond this point in time, data is only stored if this is required by the laws, regulations or other legal requirements.
 
Personal Information Collection
We may collect personal information as further described in the Privacy Policy through: (a) Personal Information provided by you, (b) Automatically Collected Information, (c) Billing Information, (d) Cookies and Other Tracking Technologies, (e) Third Party Analytics Data, (f) Mobile App-Based Data and (g) Cross-App, Cross-Web, and Cross-Device Information. 
 
Personal Information Use
We may use the information we collect from you for any lawful purpose, including, but not limited to, for providing products and services, identification and authentication, Service operation, analytics and improvements, support, contact (e.g., sending email and electronic message notifications related to use of the Service), marketing and promotions, research, sharing such information with our affiliates, first and third-party marketing, and anonymous reporting. We may combine Automatically Collected Information with other information we collect about you, to improve site functionality and the services we offer you, and for Service security, and both internal and external marketing analytics.
 
Personal Information Sharing
We do not share personal information we learn about you from your use of the Service with others except as described in this Privacy Addendum and Privacy Policy and in connection with: (i) the completion of transactions; (ii) research, promotions, sweepstakes and contests; (iii) third party marketing; (iv) a merger or sale; (v) publicly accessible information; and (vi) legal risk mitigation, legal compliance, and other lawful disclosures.
 
Changes to this policy
We reserve the right to revise, modify, or update this policy at any time. We will notify you about material changes in the way we treat personal information by sending a notice to the primary email address specified in your particular account or by placing a prominent notice on our site.
 
If you have any questions about this section or our data practices generally, please contact us using the following information and designated contact:
Name: J. Smith
Physical address: 3 Hamilton Landing, Suite 280, Novato, CA, 94949
Email address for contact: info@mashlaunch.com

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