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Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how WilliamCayetano.com (or “we” or “us”) collects, uses, and shares your information when you use our website (“Website”), or other products or features we offer. By accessing and using any of our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service.

This Privacy Policy applies to our Services that link to or reference this Privacy Policy. This Privacy Policy does not apply to websites or applications maintained by third parties that we may link to or that may be accessible to you through our Services.

INFORMATION WE COLLECT

To provide you the Services, we collect the categories of information described below.

  • Information you provide us when using our Services;
  • Information we collect automatically;
  • Information we get from advertisers, third parties, and offline sources;
  • Any other information you choose to provide to us.

Most of the data collection and uses described in this Privacy Policy are necessary in order for us to be able to provide you the Services. If you do not agree to this Privacy Policy, we will not be able to provide you usage of the Services. Some of the data collection and uses are not strictly necessary for us to provide the Services, but they are related, and our basis for such collection and processing is for legitimate interests we may have, such as to analyze and improve the Services as explained in more detail below. If you want to know how to exercise your rights to manage or delete the personal information we may have about you, please review “YOUR CHOICES” below.

INFORMATION WE COLLECT AUTOMATICALLY WHEN USING OUR SERVICES.

Device Information. We collect information from and about the devices and browsers you use that integrate with our Services. For example, we collect device type, which may include the hardware model, operating system and version, browser type and language, IP Address, plugins, app and file names and types, battery and signal strength, available storage space, unique device identifiers and mobile network information (which is treated as personal information in some jurisdictions, but which we use only to identify your geographic area and to comply with applicable laws), information you give us access to through device settings such as photos, camera, or GPS location, identifiers associate with cookies, web beacons or other technologies that may uniquely identify your device or browser. We may combine this information across different devices you use. For example, we use information collected about your use of our Services on your phone to better personalize the content (including ads) or features you see when you use our Services on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad we showed you on your phone on a different device.

Information Collected by Cookies and Other Tracking Technologies. Like most websites and applications, we and our service providers use cookies, web beacons and other technologies to collect information. Cookies are small data files stored on your hard drive or in device memory that help us and our service providers to, among other things, improve our Services and your experience by seeing which areas and features of our Services are popular. Most web browsers are set to accept cookies by default. For more information about cookies and how to disable them, please see “YOUR CHOICES” below. Keep in mind that removing or rejecting cookies could affect the availability and functionality of some Services.

INFORMATION WE GET FROM ADVERTISERS, THIRD PARTIES, AND OFFLINE SOURCES.

We may receive information about you from advertisers, app developers, and publishers, or other online or offline sources with whom you interact and who have the rights to provide us with your information. For example, advertisers, publishers, and other third parties may share how you interact with their ads, websites, or apps, how you use their services, or what purchases you make. We may combine such information with the information you have provided to us in order to provide and improve our Services. We require each of these advertisers, publishers, or other third parties to have lawful rights to collect, use and share your data before providing any data to us.

ANY OTHER INFORMATION YOU CHOOSE TO PROVIDE TO US.

You may provide other information directly to us. For example, we may collect information when you fill out a form, update your account, interact with the Services, apply for a job at our company, communicate with us via third-party social media sites, request customer support or otherwise communicate with us.

VISITORS OUTSIDE THE UNITED STATES

This Privacy Policy is intended to cover collection of information on our Services from residents of the United States. The data protection and other laws of the United States might not be as comprehensive as those in your country. Where permitted by applicable law, we may transfer the personal data we collect about you to other jurisdictions other than where you reside that may not be deemed to provide the same level of data protection as your home country for the purposes set out in this Privacy Policy.

By visiting or using our Services in any way, you acknowledge and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy, regardless of the laws of your country of residence.

To the extent the laws of another jurisdiction apply to your data or use of our Services, we will comply with such laws. For example, for European Visitors, read the “EUROPEAN VISITORS – COOKIES NOTICE.” section of Cookies and Other Technologies to learn more about our use of cookies and similar technologies with visitors from the EEA.

EU Visitors

If you are an EU citizen or UK citizen, you may have additional rights under the EU General Data Protection Regulation or the UK-GDPR (collectively, the “GDPR”) with respect to your Personal Data, as outlined below. For this section, 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. We will be the controller of your Personal Data processed in connection with the Services. Note that we may also process Personal Data of our customers’ end users in connection with our provision of certain Services, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.

The legal bases for which we collect and use the information described above depends on what the information is and why we collected it. The four bases upon which we rely include:

  • Contract. This means we need the information to perform our contracted Services with you. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require that data.

  • Legitimate Interests. This means we have a legitimate interest that does not outweigh your privacy rights. When we collect and process information based on our legitimate interests, we consider how we can accomplish what we need to in a way that is the least obtrusive on your privacy. For example, it is in our interest to protect your safety and security in the Services, so we collect and use information that has been flagged by users or requested by law enforcement; to make sure you are satisfied with how the services work, troubleshoot technical problems or develop new features, we collect and use information about how you and others use the services and to respond to your service inquiries, we collect and use information in that request and, if relevant to the inquiry, information about how you access and use the services.

  • Legal Obligation. We may need to use your personal information to comply with a law enforcement preservation request, subpoena, or other legal process or to protect the rights of other users.

  • Consent. If we have no other legal basis for collecting or using your information, we will ask you for consent for a specific purpose. If we do, you have the right to withdraw consent at any time. Withdrawing your consent will not apply to any processing conducted in reliance on lawful processing bases other than consent.

In addition to other rights detailed in the policy (such as requesting deletion, correction or updating of your personal information), EU and UK citizens have certain rights regarding your personal information, including:

  • Right to Object or Restrict Processing. You have the right to object to or restrict our use of your personal information for direct marketing purposes or under certain circumstances when the legal bases for using your information is based upon our legitimate interest.

  • Right to Access or Erasure. You have the right to have your personal data erased and no longer processed. You also have the right to access the Personal Data we have collected about you. You can send us a request to delete your account or access your information by completing our Data Access & Erasure. Upon receiving the request, we will make a reasonable effort to delete your personal information from the Service and from our internal network within a reasonable period of time as long as we are not obligated to preserve your information due to things like law enforcement preservation requests, subpoenas, investigations, litigation, or otherwise meet any of our other legal obligations. We may also retain depersonalized information after deletion.

  • 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 the Services.

As explained above, personal data collected in the EU or UK may be transferred to, and/or stored at, a destination outside of the EU and/or UK and processed by employees operating outside of the EU and/or UK who work for us, one of our business partners, or service providers. We have implemented sufficient GDPR compliant procedures to secure the transfer of your personal data to the United States. We utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to the United States.

CHILDREN’S INFORMATION

The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from children under 13.

Additionally, we do not knowingly collect or solicit personal data from anyone under the age of 16 in countries subject to the EU GDPR, unless exempted by individual country exceptions.

If you are under 13, or 16 where applicable, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under the required minimum age, we will delete that information as quickly as possible.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this Privacy Policy, we will post a notice to our Services and will update the notice’s effective date. We will give you an opportunity to review the changes before they go into effect. Your continued use of the Services following notice of the changes constitutes your acceptance of the changes, so we encourage you to review the Privacy Policy whenever you use our services. If you do not agree to the updated Privacy Policy, you may delete your account(s).