Introduction. Hi, we're SURE2ODD ('we', 'us' or 'SURE2ODD') and welcome! We're happy to have you here and we hope you enjoy your stay on our website (the 'Site').
What type of personal information do we collect?
We collect certain personal information about visitors and users of our site. The most common types of information we collect are things like: user names, member names, email addresses, other contact details, payment information such as payment agent details, transactional details, support queries, and web analytics data. For verification purposes, and to protect our members, we may request personal documents such as government IDs.
How we collect personal information
We may collect personal information directly when you provide it to us, automatically as you navigate through the Site or through other people when you use services associated with the site.
When you provide personal information to us via the Site you're consenting to us collecting and using that information in line with this Policy and the user terms . You are likely to provide personal information when you complete membership registration and buy or provide tips or services on our site, subscribe to a newsletter, email list, submit feedback, write a review, enter a contest, fill out a survey, or send us a communication.
If you choose not to provide personal information, we may not be able to provide you with our services and you may not be able to carry out transactions or access the full range of features available through our site.
Personal information we collect about you from others
Although we generally collect personal information directly from you, we may on occasion also collect information about you from other people (such as the payment provider account details required to process a transaction) and by using tracking technologies such as cookies, web beacons and other web analytics software or services.
How do we use personal information?
Without your permission, we shall not rent, sell, or disclose personal information about you with third parties, except when necessary to provide services that you have requested or contracted us to perform, and as otherwise provided in this Policy. We may use your personal information in order for us to:
1. operate the Site and provide you with services described on the Site, like to verify your identity when you sign in to our Site, to facilitate and process transactions that take place on the Site, to respond to support tickets and to help facilitate the resolution of any disputes.
2. customise our services and website, like advertising that may appear on the Site, in order to provide a more personalised experience.
3. update you with operational news and information about our Site and services like to notify you about changes to our Site, website disruptions or security updates.
4. provide you with information that you request from us or, where we have your consent to do so, provide you with marketing information about products and services which we feel may interest you.
5. carry out technical analysis to determine how to improve the Site and services we provide.
6. monitor activity on the Site, like to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Site.
7. manage our relationship with you, like by responding to your comments or queries submitted to us on the Site or asking for your feedback or whether you want to participate in a survey.
8. manage our legal and operational affairs.
9. train SURE2ODD staff about how to best serve our community; and
10. provide general administrative and performance functions and activities.
When may we disclose your personal information?
We may disclose personal information to people like:
1. subcontractors and service providers who assist us in connection with the ways we may use personal information (as set out above).
2. our professional advisers (lawyers, accountants, financial advisers, etc).
3. regulators and government authorities in connection with our compliance procedures and obligations.
4. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase; and
5. other people where we are authorised or required by law to do so.
We use a network of global subcontractors and service providers in order to ensure that we maintain the best possible service standards. Some of the subcontractors and service providers to whom we may disclose your personal information, like service providers who provide us with cloud storage solutions, may be based in different regions or countries. In order to protect your information, we will disclose your personal data only to persons or organizations that we believe maintain adequate data security, and will respect data subjects' rights over their personal information.
How do we store your personal information?
We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure location. Personal information that we store is subject to security and access controls, including username and password authentication and data encryption where appropriate.
How can you access or correct your personal information?
You can access some of the information that we collect about you by logging in to your account. You may request access to other information we hold about you and to request corrections of any errors in that information. You may also request us to close your account and delete your personal information. We may accede to such requests if the personal information is no longer necessary to render in relation to the purpose for which it was collected, and if otherwise there is no compelling reason to continue processing such data. However, we may refuse requests to delete data under the following circumstances:
to exercise the right of freedom of expression and information;
to comply with a legal obligation or when retention of data is required by official authority;
for purposes required by the public interest; or
the exercise or defense of legal claims.
To make a request regarding your personal data, contact our privacy champion using the contact details at the end of this Policy. We will require you to verify your identity before we respond to a data request. We will endeavor to respond to such requests within 30 days, and provide the information in a commonly used electronic format. If the data request is complex, we may extend this period to 60 days. For data requests that are manifestly unfounded, excessive or repetitive, we may charge a reasonable administrative fee to respond.
Choices regarding control of your personal information
Where we have your consent to do so (e.g if you have subscribed to one of our e-mail lists or have otherwise indicated that you are interested in receiving offers or information from us), we may send you marketing communications about products and services that we feel may be of interest to you. You can 'opt-out' of such communications if you would prefer not to receive them in the future.
If your e-mail address has changed and you would like to continue to receive our e-mails, you will need to access your account and update your e-mail address information in your account and sign-up again for those e-mails that you want to receive.
If we send e-mails with commercial content we will generally include an "unsubscribe" facility that you can use to opt-out of further communications - to opt-out, just follow the instructions in the e-mail. We might not include an opt-out facility in important operational and service-based e-mails concerning things like your purchases, the user terms, important updates and need-to-know messages. By using our Site you agree that we do not need to include opt-out facilities in those messages.
At any time, you may request us to stop processing your personal data for direct marketing purposes.
Information about minors
You must be at least 18 years old to use the Site. If we suspect that you are younger than 18, we may terminate your account and delete or safeguard your personal information accordingly.
Information you make public or give to others
When we need to update this Policy
We may need to change this Policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices. When we do amend the Policy, the changes will be effective straightaway. We'll usually publish information about changes to be made to this Policy on our Site - but please be aware that it is your responsibility to check in and make sure you keep up to date with any changes to this Policy.
How can you contact us?
If you have any questions about our privacy practices, please email our privacy champion as follows: [email protected]
If you have any concerns about how we have been managing your personal information, or if you think we have not been complying with applicable privacy law, you can make a complaint in writing to our privacy champion. We will consider your complaint and contact you to resolve the matter.
We're really glad you made it to the end of the Policy, because knowing this stuff is the best way to understand how your personal information is used and how to best manage it!