Last Updated: July 1, 2018
For purposes of data protection laws, Varsityplaza LLC, located at 44095 Pipeline Plaza, Suite 340, Ashburn, VA 20147, is the “data controller” of your information.
Information We Collect
We may collect and store information about you in various ways. For example, we may collect information that you provide to us, information that we automatically collect through your use of the Site, and information that we collect from publicly available sources or third parties.
Please note that in some cases, we need certain types of information so that we can respond to your requests or otherwise communicate with you regarding our services. If you do not provide us with such information, or ask us to delete it, you may not be able to obtain the information you are seeking.
Information You Provide Us. We collect and store your contact information when you send us requests or questions via forms, email, or any other manner. We also collect your information in the course of your communications and dealings with us (including on the Site, over the phone, and by mail and email). The types of data we collect include your name, address, email address, and phone number.
Information We Automatically Collect. When you use the Site, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to automatically collect information. When you use our Site we may collect your IP address, browser types, browser language, operating system, the state or country from which you accessed the Sites, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site, error logs, and other similar information.
This information is used to improve the performance and content of our Site.
We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
We may use third-party Web analytics services in connection with the Site, such as those of Google Analytics. These service providers use a variety of tracking technologies such as cookies to analyze how users use the Website and Service. The information collected (described above in “Cookies”) will be collected directly by these service providers to evaluate your use of the Website and Service. For more information on how Google Analytics uses data from our websites and how you can control the information sent to Google, click here. To learn about opting out of Google Analytics, please click here. Because these opt outs are cookie-based, please note that if you get a new computer or device, install or start using a new browser, or erase or alter your browser’s cookie file, you may need to opt out again.
How We Use and Share Information
We, or our service providers, use your information for various purposes depending on the types of information we have collected from and about you. We use your information:
• For the purposes for which you provide it;
• To communicate with you, including to respond to your request for information;
• To improve the Site;
• For internal recordkeeping purposes;
• To secure and troubleshoot issues with the Site; or
• To protect the rights of Offerwise or others.
We may share your information:
• With our service providers;
• With our affiliates;
• As part of a merger, acquisition, or sale of some or all of our assets (including for due diligence regarding a transaction) or in the unlikely event of an insolvency, bankruptcy, or receivership; or
• With other parties, with your consent or at your direction.
Legal Bases for Use of Your Information
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:
• To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to communicate with you about how you can engage our services.
• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
• Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Site; providing security for the Site and our services; marketing; making and receiving payments; and preventing fraud.
• Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities).
California Residents: Your California Privacy Rights
Offerwise does not disclose your personal information to third parties for the purpose of directly marketing their services to you unless you first agree to such disclosure. If you have any questions regarding this policy, you may contact us using the information in the “Contacting Us” section below.
Data Subject Rights
The laws in some jurisdictions requires us to provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. To the extent those laws apply to you, your controls and choices may include:
• Obtain access to or a copy of certain personal information we hold about you
• Prevent the processing of your personal information for direct marketing purposes
• Update personal information which is out of date or incorrect
• Delete certain personal information which we are holding about you
• Restrict the way that we process and disclose specific personal information about you
• Transfer your personal information to a third-party provider of services
• Revoke consent that you previously provided for the processing of your personal information
For more information on how to exercise these rights, contact us using the information in the “Contacting Us” section below. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
We take technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to protect your information, we cannot guarantee its absolute security.
Retention of Your Information
We keep your information for no longer than necessary for the purposes for which it is processed and/or as required to comply with applicable laws.
Links to Third-Party Websites
This site contains links to other sites that are owned or operated by others (“third-party websites”). We are not responsible for the privacy and security practices of sites not owned by Offerwise. We encourage you to read the privacy and security policies of these third-party websites.
This site is not intended for use by children under the age of 13 and we do not knowingly collect personally identifiable information (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13. If you are the parent or guardian of a child under 13 who has provided her or his information to us, please contact us through one of the means listed below and we will seek to remove that information.
We do not knowingly collect data from EEA residents under the age of consent set by applicable data protection law. If we learn that we are processing data of such an individual, we will halt such processing and will take reasonable measures to promptly remove applicable data from our records.
International Users and Consent to Transfer
Where required, we will use appropriate safeguards when transferring your data outside of the EEA. For more information about these safeguards, please contact us as detailed in the “Contacting Us” section below.