Privacy

Proxximity Privacy Policies

Your data is yours at all times. We are not allowed to share it or use it
if it is in any way understandable to which person it refers.
Effective as from: July 2nd, 2018

 

1. INTRODUCTION

1.1.        Proxximity Ltd. (“Proxximity” or “we”) treats all of the personally-identifiable information about you that we collect and process (hereinafter referred to as “Personal Data”) with utmost care and security. This Proxximity Privacy Policy (the “Privacy Policy”) explains what types of data we collect about you and why, what we do with the data we collect, if and how we share it, the choices, which you have regarding our use of your Personal Data and how you may access and update it.
1.2.        More information about the Maltese laws applicable to privacy and data protection can be found on the website of the IDPC at www.idpc.org.mt.

2. SCOPE OF PRIVACY POLICY
2.1.        This Privacy Policy applies to the proxximity.com website, including all of its subpages, subdomains and successor pages, and the Proxximity App (collectively referred to as the “Proxximity Website”), as well as to all of the services offered by Proxximity (referred to as the “Proxximity Services”). This Privacy Policy does not apply to any website, product or service of any third-party company, even if the Proxximity Website links to the website of such company. Make sure that you get fully acquainted with the privacy statements of any third-party companies before you use their websites, products or services and before you provide your Personal Data to them.
2.2.        By making use of the Proxximity Website and the Proxximity Services you are agreeing to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you should not visit the Proxximity Website or make any use of the Proxximity Services. Your continued usage of the Proxximity Website and/or the Proxximity Services will indicate your acceptance of this Privacy Policy.
2.3.        The term “Personal Data” as used in this Privacy Policy refers to any data which can be used for the purpose of identifying a specific natural or juridical person, such as name, address, email address, or phone number. Personal Data does not include information which has been aggregated or made anonymous, thus making it unable to be used for the purpose of distinguishing a specific person.

3. COLLECTION OF PERSONAL DATA
Proxximity may collect Personal Data in order to be able to provide the Proxximity Services to you. We collect Personal Data in two ways:
3.1.        When you provide Personal Data directly to us. We are required to collect information about you if you purchase Premium Content directly from the Proxximity Website. This information may include:

  • personal contact information: such as name, email address, phone number, etc.;
  • profile information: such as username, password, account image, etc.;
  • preferences information: such as notification and marketing preferences, etc.;
  • content: such as any personal sensitive information that you choose to create, input, submit, upload, store or display in the process of using our Proxximity Services, etc.;
  • other submissions: such as information that you may submit to us when you communicate with us via third party social media sites, etc..

3.2.        When you use the Proxximity Website and/or the Proxximity Services. We may gather certain information regarding your visits to the Proxximity Website and the use you make of the Proxximity Services in order to improve and optimize your user experience, which can be categorized as follows:

  • web logs:  we may collect information about internet protocol (IP) addresses, browser types, geographical location, session information, browsing behavior, certain software and hardware attributes disclosed by a browser, etc.;
  • analytics information:  we may collect analytics information such as the specific features of the Proxximity Services that you use, the specific functions you perform while using the Proxximity Services, and information about your use of the payment and downloading functionalities that form part of the Proxximity Services, for the purpose of helping us to better understand your preferences in order to improve our Proxximity Services, etc.;
  • cookies:  Proxximity may use cookies to allow you access to the Proxximity Website and the Proxximity Services, to improve and customize the Proxximity Services and your customer experience and to understand which areas and features of the Proxximity Website and of the Proxximity Services are most popular. For more information on the types of cookies we use and how you can adjust your cookies preferences, please refer to Article 8 below.

4. USE AND PROCESSING OF PERSONAL DATA
4.1         We may use the information we collect about you for a variety of general purposes, including:

  • to provide, operate, maintain, improve and promote the Proxximity Services to you;
  • to enable you to access the Proxximity Services, including by downloading the Proxximity App and accessing our Free Content and Premium Content;
  • to process and complete transactions, including purchase confirmations, as well as to send you related information and invoices;
  • to provide customer support services to you, to respond to your questions and requests, and to send you technical or administrative updates and messages;
  • to send you communications with updates regarding the Proxximity Website, the Proxximity Services, as well as offers, promotions, and events;
  • to monitor and analyze trends, usage and activities in connection with the Proxximity Services for marketing and advertising purposes;
  • to prevent fraudulent activities and unauthorized access to the Proxximity Website and the Proxximity Services; and
  • to generate aggregated anonymized analyses of user behavior.

4.2.        In addition to the purposes stated in Article 4.1., we may make use of analytics information in order to better understand how the Proxximity Services are used and how they can be improved further.

5. SHARING AND DISCLOSURE OF PERSONAL DATA, THIRD PARTIES
5.1.        We do not share or disclose your Personal Data or content with any third parties, except as provided under this Privacy Policy.
5.2.        We work with certain third-party service providers, which may provide hosting, application development, payment processing, storage, virtual infrastructure and other services to us from time to time. These third-party service providers may have access to your Personal Data in order to be able to provide their services to us and in doing so we seek to ensure that your Personal Data is treated in accordance with this Privacy Policy. Third-party service providers are prohibited from using the Personal Data they have access to for purposes other than as reasonably necessary for the provision of their services to us.
5.3.        The Proxximity Website and the Proxximity Services may contain links to other websites, whose privacy practices may differ from our own. If you submit your Personal Data to any third-party website, your data is governed by the privacy policies of that website. Therefore you should carefully read the privacy policy of any website you visit before submitting your Personal Data to it.
5.4.        We may disclose your data (including your Personal Data) to third parties if such disclosure is reasonably necessary for the purpose of

  • complying with applicable laws, regulations, court orders, legal processes or governmental requests,
  • preventing harmful or illegal activities and, in urgent circumstances, protecting the personal safety of our employees, our customers, and the public,
  • protecting the security and integrity of the Proxximity Services and defending the rights or property of Proxximity, and
  • where reasonable, maintaining, updating or otherwise implementing our data security measures, equipment, technical operations and the like.

5.5.        You indicate your acceptance of this Privacy Policy and the Proxximity Terms and Conditions of Use by checking the “I Agree” box when downloading the Proxximity App.
5.6.        The Proxximity Website and the Proxximity Services may contain social media features or widgets (such as the Twitter “tweet” button) which may collect information including but not limited to your IP address and the page you are visiting on the Proxximity Website; they may also set a cookie to enable the feature or widget to function properly. Social media features or widgets are hosted by third parties directly on the Proxximity Website, and your interactions with them are governed by the privacy policies of the companies providing these features or widgets.
5.7.        We may display on the Proxximity Website testimonials of customers of Proxximity who are satisfied with the Proxximity Services. With your explicit consent and confirmation we may post your personal testimonial on our Proxximity Website too, along with your name.
5.8.        We may transfer your data (including your Personal Data) in connection with or in the process of negotiating any future fundraising or sale, assignment or other transfer involving the Proxximity business or any part thereof, or as part of a security audit.
5.9.        We may also share with third parties aggregated or anonymized data that does not directly identify you or any of your Personal Data.

6. PROXXIMITY WEBSITE VISITORS
6.1.        You are not required to provide any Personal Data to us when browsing the Website. We may, however, gather non-personally-identifiable data about you, including but not limited to your IP address, the pages you visit on the Proxximity Website, and the dates and times when you visit the Proxximity Website. We collect such non-personally-identifiable data for the purpose of monitoring and improving the Proxximity Website and the Proxximity Services.
6.2.        When visiting the Proxximity Website you may voluntarily provide your Personal Data, including inter alia your name and email address, for the purpose of requesting information from us, or for any other purpose stated on the Proxximity Website.

7. DATA STORAGE AND PROTECTION
7.1.        We take reasonable steps to ensure that all Personal Data that we collect is transferred and stored in a secure manner. In doing so we seek to ensure, as far as reasonably practicable, that the Personal Data we collect and store is protected from misuse, unauthorized access, modification or disclosure. We do so via methods for safeguarding sensitive information including access limitation, data encryption technology, and firewalls.
7.2.        Data collected by Proxximity may be stored and processed in Malta or elsewhere. We uphold and maintain strict procedures for protecting data stored in our servers and access is limited to those employees whose work-related duties involve working with such data. You acknowledge and agree that by providing Personal Data to Proxximity you consent to the transmission of data (including Personal Data) over international borders, as may be necessary for processing your requests.

8. COOKIES
8.1.        A cookie is a small file, which is temporarily stored in the memory of your computer or mobile device. Proxximity uses cookies to improve the performance of the Proxximity Website and the Proxximity Services and to enhance your user experience. We use different types of cookies and a description of each type is provided below.
8.2.        Strictly necessary cookies:  These cookies are needed for the functioning of the Proxximity Website and the Proxximity Services, as they enable us to identify your device when you seek to download the Proxximity App, and without them the Proxximity Website cannot function and the Proxximity Services cannot be provided to you.
8.3.        Functionality cookies:  These cookies remember information about choices and preferences you have made and allow us to tailor the Proxximity Website and Proxximity Services to you and improve your experience.
8.4.        Performance cookies:  These cookies are aimed at collecting information about how visitors use the Proxximity Website, including which pages are most popular and whether error messages are encountered on any of the web pages. Performance cookies enable us to improve the Proxximity Website and the Proxximity Services and to provide a high-quality experience to you as a user. The information collected by these cookies does not identify individual users and is held on an aggregated basis.
8.5.        Targeting cookies:  These cookies collect information about your browsing habits in order to deliver advertising to you that is tailored to your interests. They are also used to determine the effectiveness of an advertising campaign and may determine the amount of times you see an advertisement. In accordance with applicable laws and regulations, we only place targeting cookies if you have given your permission for this. You can give your permission by ticking the appropriate box on the ‘Cookie Statement’, which is shown at the time of your first visit to our Proxximity Website. The statement may re-appear again if a particular cookie has been rejected, deleted, or has expired.
8.6.        Cookies may also be placed on the Proxximity Website by third parties, such as Google, Twitter, Facebook, etc. The privacy policy of the relevant third party will govern the use of these third party cookies and Proxximity is not responsible for any misuse of Personal Data and cookies by such third parties.
8.7.        You can adjust the privacy settings in your web browser in order to limit or block the cookies that you receive during your visits to our Proxximity Website. Note that doing so may have a negative impact on your browsing experience and may result in the deletion of cookies storing your preferences and personalized settings for websites which you regularly visit. It is possible to keep desired cookies because your browser may allow you to select which websites are allowed to use cookies and which are not.

9. UPDATING YOUR PERSONAL DATA
9.1.        Proxximity aims to keep your Personal Data as accurate as possible. You may at any time correct, update, amend or remove your Personal Data by contacting us directly, using the contact information outlined on the Proxximity Website. Please note that for the purposes of ensuring the safety of sensitive and Personal Data, you will be requested to provide sufficient evidence of your identity at the time of your request before any Personal Data records will be made available to you by Proxximity.

10. Credit Card Security

We know customers are concerned about credit card security. We use one of the worlds largest funds transfer agencies - PayPal.
If you choose to use a PayPal account, your personal credit card information will not be given Proxximity LTD

11. CHANGES TO THIS PRIVACY POLICY
11.1.     Proxximity reserves the right to change this Privacy Policy from time to time. If we make any changes to the Privacy Policy, we will notify you by updating the effective date at the top of this Privacy Policy. If any material changes are made to this Privacy Policy, we will provide you with additional notice, such as via a notice placed on the homepage of the Proxximity Website or email notification.
11.2.     Your continued use of the Proxximity Website and the Proxximity Services following the notification of changes to this Privacy Policy by Proxximity will indicate your acceptance of these changes. If you disagree with any updates of this Privacy Policy, you must stop using the Proxximity Services and visiting the Proxximity Website.

 

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