GOLDUNE PRIVACY NOTICE
Effective: October 20, 2020
Please read this Privacy Notice carefully. It provides important information about your personal information. It also tells you about your rights under applicable privacy laws.
Table of Contents
- Changes to this Privacy Notice
- Information We Collect
- Payment Processing
- Sensitive Data
- Children’s Privacy
- Using Your Personal Information
- Sharing Your Personal Information
- Direct Marketing Communications
- Your Choices
- Data Retention and Security
- External Websites
- Notice to Users Located Outside the United States
- Contact Us
Goldune, Inc., a Delaware corporation (collectively, “Goldune”, “we”, “us” or “our”) owns and operates the Goldune marketplace platform (the “Marketplace”) located at http://www.goldune.com (the “Site”), that enables users to purchase sustainable goods and products (the Platform and Site, collectively, the “Services”).
This Privacy Notice is intended to help you better understand how we process your personal information, and governs how Goldune may use, transfer, store and disclose such personal information in connection with your use of the Services.
“Personal information” or “personal data” means any information about an individual from which that person may be identified. For example, it may include your name, telephone number, email address, or payment information, and in some jurisdictions your IP address. It does not include data from which the identity of an individual has been definitively removed along with any identifiers connected to such individual (also known as anonymous or anonymized data).
Goldune collects personal information if you:
- Visit the Site;
- Register and create a customer account for the Services (an “Account”);
- Access and/or use the Services;
- Purchase any goods and/or products sold through the Marketplace (“Products”);
- Sign up to receive marketing materials; or
- Directly communicate with us.
BY ACCESSING OR USING THE SERVICES, OR SUBMITTING INFORMATION IN CONNECTION WITH YOUR USE OF THE SERVICES, YOU ACKNOWLEDGE AND AGREE THAT YOU HAVE READ THIS PRIVACY NOTICE.
CHANGES TO THIS PRIVACY NOTICE
Goldune reserves the right to update or modify this Privacy Notice at any time. All updates and modifications to Privacy Notice will be effective from the day they are posted on the Site at http://www.goldune.com/privacypolicy (except as stated below). If we make any material changes to Privacy Notice, we will notify you of these changes by sending a notification to the email address we have on file for you, or, if we do not have an email address on file, by posting a prominent notice of the changes on the Site. It is your responsibility to regularly visit and review the Privacy Notice. If you do not agree to any updates or modifications to the Privacy Notice, terminate your Account (if applicable) and do not use or access the Services (or any part thereof). Your continued use of the Services after we have posted the updated Privacy Notice, or, in the event of material changes, ten (10) days following the date Goldune first notifies you of such material changes either through email or the date we posted the notice of such changes on the Site, as applicable, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.
INFORMATION WE COLLECT
How and what personal information we collect from you depends on how and why you use the Services. For instance, the information that you provide when you visit the Site is more limited than the information that you provide if you purchase Products or create an Account.
- Information Collected Directly
In connection with the above-mentioned activities, Goldune may collect the following information:
- Your first name and last name;
- Your email address;
- Your postal address and phone number;
- Your Account log-in credentials;
- Certain payment information when you purchase a Product (however, this only includes partial payment or credit card information, which is processed and stored exclusively by our third-party payment processor as described here).
- Other information you may provide by filling out forms or by contacting us (such as your feedback or other communications with us).
- Information Collected Indirectly
Cookies and Similar Technologies
We or authorized third parties collect certain information by automated means using cookies, web beacons, and server logs for analytic purposes. Goldune tracks users use of the Services, but does not track users across third party websites. A cookie is a small text file that is stored on a user's computer for record-keeping purposes. When you visit or access the Services, we may by means of cookies, beacons, tags, scripts, and/or similar technologies automatically collect technical information about the devices and software you use to access the Services, such as the type of Internet browser or mobile device you use, the website or source that linked or referred you to the Services, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, and other similar technical information. Typically, all technical, analytics, and usage information is gathered by Goldune in anonymous form and does not identify you personally.
We use both session ID cookies and persistent cookies. These technologies (or a combination of them) are used to help us:
- Compile statistics and analytics about your use of and interaction with the Services, including details about how and where the Services are accessed, how often you visit or use the Services, the date and time of your visits, your actions on the Services, and other similar traffic, usage, and trend data, which allow us to better understand the functionality of our mobile software on your device and gain insights about how mobile software is used in order to improve your experience;
- Gather important functionality, testing, and performance data about the Services, including performance data related to the Services, such as networking activity, CPU load, and resource usage, among other relevant data;
- Moderate user behavior on the Services, such as protecting against fraud and other inappropriate activities;
- Gather demographic information about our user base; and
- Perform other similar functions.
We may use third party advertising partners who use targeting/advertising cookies to deliver advertisements that are more relevant to you and your interests (e.g., Facebook, Instagram, Google and Twitter). They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. We use the third party service providers listed below that use these cookies to:
- Keep track of how many visitors click on the advertisement;
- Keep track of how many orders are placed by way of the advertisement;
- Advertise Goldune and our products and services across the Internet; and
- Tailor our marketing to better suit your needs and only display ads that are relevant to you.
Please refer to the privacy policies linked below of the third party advertising services currently utilized through the Services:
You may manage your cookie preferences as further explained in Your Choices.
- Information Collected from Third Parties
In some instances, we process personal information from third parties, which consists of:
- Data from our partners, such as transactional data from providers of payment services; and
- Data from our third party service providers who we have engaged to help provide the Services as described here.
- Aggregated Data
In connection with your access and use of the Services, we process “Aggregated Data”, such as statistical or demographic data. Aggregated Data may be derived from personal data, but is not considered personal data under the law if it does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific feature of the Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be processed in accordance with this Privacy Notice.
We do not directly collect your payment information and we do not store your payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions.
Goldune does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, and biometric data to use the Services.
Goldune does not target the Services to persons under the age of 13 and does not knowingly collect personal data from minors. Therefore, we ask you not to provide us with personal information of persons under the age of 13. If we learn that personal information of persons under 13 years of age has been collected on or through the Services, then we may deactivate the account or otherwise terminate access to the Services and/or make the content inaccessible.
USING YOUR PERSONAL INFORMATION
Depending on how you use the Services, we use your personal information in the following instances:
- To perform and provide the Services to you;
- Deliver direct marketing communications to you regarding our products and services that we may think are of interest to you;
- Respond to your queries and requests, or otherwise communicate directly with you;
- Detect any fraudulent or illegal activity against you and/or Goldune;
- Perform system maintenance and upgrades, and enable new features;
- To comply with a legal or regulatory obligation (for example, keeping records of our sales for tax compliance).
SHARING YOUR PERSONAL INFORMATION
Aside from disclosing your information to those of our personnel who are authorized to process the information in order to provide the Services and who are committed to confidentiality, we disclose your personal information only to the third parties as described below.
Third Party Service Providers
We share personal information with third parties that provide services to help us provide the Services and operate our business. Depending on how you use the Services, the following categories of third parties collect data on our behalf or receive personal information:
- Hosting services providers;
- Analytics providers;
- Advertising and marketing partners;
- Merchants for the Products;
- Payment providers;
- Shipping providers;
- Customer support providers;
- Providers of business operations and communication tools;
- Other third-party service providers that help us provide features and functions for the Services; and
- Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.
For a list of all third-party service providers we use, please contact us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, unless the data is rendered fully anonymous.
- Business Transfers
If Goldune enters into a merger, acquisition or sale of all or a portion of its assets or business, your personal information may be one of the transferred assets. Should such a sale or transfer occur, Goldune will require the buyer to treat your personal information in a manner that is consistent with this Privacy Notice.
- Affiliates and Subsidiaries
Personal information that we collect about you through the Services may be shared with the employees, contractors, and agents of Goldune and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Services that we offer to you. We obligate the employees, contractors and agents of Goldune and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.
- Legal Disclosures
If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States. Under such circumstances, we will attempt to provide you with prior notice that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we notify the individual when it has expired or once we are authorized to do so.
Note that if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.
DIRECT MARKETING COMMUNICATIONS
If you have not otherwise opted out, or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Services. For instance, when you request additional information regarding the Services or sign up for our newsletter, we may ask if you wish to opt in to receive marketing communications from us for the Services. This is what we call direct marketing. We carry out direct marketing by email. We obtain consent to send you such communications where required under applicable local laws.
If you no longer wish to receive marketing communications, you have the right at any time to opt out. The easiest way to opt out is to use the unsubscribe link that you will find at the bottom of each communication. You may also manage your direct marketing preferences as further explained in Your Choices.
- Updating and Correcting Personal information
If you would like to correct or update certain personal information (such as your contact information) please contact us at firstname.lastname@example.org and we will use reasonably efforts to correct and/or update such information.
- Direct Marketing
You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You cannot opt out of receiving transactional e-mails related to the Services (e.g., requests for support).
- Cookies & Targeted Advertising
With respect to your choices regarding cookie and other tracking technologies, most web and mobile device browsers automatically accept cookies; however, you may manage your cookie preferences, by altering the cookie settings in your browser settings at any time.
While tracking is widespread over the internet, there are things you can do to minimize these activities, as explained here:
- You may download the Google Analytics opt-out browser add-on here.
- You may turn on the Do Not Track (“DNT”) setting in your browser, which will enable your browser to send a special signal to websites, analytics companies, plug in providers, and other web services you encounter while browsing to stop tracking your activity. To turn on your DNT signal, please visit https://allaboutdnt.com/#adjust-settings. Please note that not all companies will respond to or honor DNT signals.
You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. Please note, however, that by blocking or deleting cookies used on the Services, you may not be able to take full advantage of the Services. In addition, please note that even if you opt out of targeting/advertising cookies using the mechanisms above, advertisements may still be visible to you when using the Services.
Goldune does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use the Services.
DATA RETENTION AND SECURITY
- Data Retention
Your personal information is processed for the period necessary to fulfill the purposes for which it is collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.
In order to determine the most appropriate retention periods for your personal information, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, and applicable legal requirements.
In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.
- Data Security
We have put in place reasonable and appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. For example, we use encryption, secure socket layer, firewalls, and password protection. In addition, we limit access to personal information to those employees, agents, contractors and the third parties who have a business need-to-know.
We also have procedures in place to deal with any suspected data security breach. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and while we take reasonable steps to provide secure services, by using the Services, you understand and assume the risks associated with your activities on the internet.
NOTICE TO USERS OUTSIDE THE UNITED STATES
Goldune and its servers used to provide the Services are operated in the United States. If you are located outside of the United States, please be aware that your information, including your personal data, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.
Should you have any questions, concerns or a complaint about this Privacy Notice, please contact Goldune via email at email@example.com or by writing to us at the following address:
P.O. Box 93,
7615 Stage Rd,
San Gregorio, CA 94074
Attn: Privacy Officer
© 2020 Goldune, Inc. All rights reserved.