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1. INTRODUCTION
This Privacy Policy applies to www.WhoEasy.com ("Website") and any services provided by us to you through the Website (collectively, the "WhoEasy Service") provided by R E Y A LLC dba WhoEasy ("WhoEasy," "we", "us" or "our"). This Privacy Policy describes how we collect and use the personal information you provide on or through the WhoEasy Service. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy is only applicable to WhoEasy Service, and not to any other websites or services that you may be able to access from the Website or through the WhoEasy Service, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.
This Privacy Policy is a part of and incorporated into the WhoEasy Terms of Use located at www.whoeasy.com/terms (the "Terms"). If any provision of this Privacy Policy is inconsistent or conflicts with any provision in the Terms, this Privacy Policy will control with respect to the subject matter hereof. Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the meanings given to them in the Terms.
2. YOUR CONSENT
This Privacy Policy applies to information we collect: (i) through your access and use of the WhoEasy Service; and (ii) in e-mail, text and other electronic messages between you and us. It does not apply to information collected by: (a) us offline or through any other means, including on any other website operated by us; or (b) through any website, application, or content (including, but not limited to, advertising) of any third party (including, but not limited to, our affiliates and subsidiaries) that may link to or be accessible from WhoEasy Service.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use or access the WhoEasy Service. By accessing or viewing the WhoEasy Service, or submitting Personal Information through the WhoEasy Service, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information in accordance with this Privacy Policy. You understand that by providing us Personal Information, you allow us to identify you. Some of the services we provide may be hampered if you do not provide us the necessary Personal Information.
3. HOW WE DEFINE PERSONAL INFORMATION V. ANONYMOUS INFORMATION
We collect both Personal Information and Anonymous Information, each as defined below, in connection with your use of the WhoEasy Service.
"Personal Information" is information that allows someone to identify or contact you, as well as any other non-public information about you that is associated with or linked to any of the foregoing, and can include, for example, an individual's first and last name, phone number, and e-mail address.
"Anonymous Information" means data that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons.
4. PROTECTING YOUR PRIVACY
We do not share, rent or sell your account information to any third party, except as expressly set forth in this Privacy Policy. Please help us protect your privacy by keeping your account information safe. Do not disclose your account password or logon information to anyone and keep changing it periodically. If you find that an account depicting your personal or business profile or information has been created on the WhoEasy Service by an unauthorized individual, please contact us immediately at contact@whoeasy.com to request for its removal.
5. INFORMATION COLLECTION PRACTICES
Registration Information Collected
When you register an account with the WhoEasy Service, you are required to provide us Personal Information. We collect and store the following Personal Information in connection with the registration of an account: your first and last name, email, and billing information. You understand that by providing us such Personal Information, you allow us to identify you. Some of the services we provide may be hampered if you do not provide us the necessary Personal Information.
We may use the Personal Information you submit during the registration process to send you services-related communications.
Payment and Billing Information Collected
When you submit payment for access and use of the WhoEasy Service our third party payment processor will collect, on our behalf, your name, billing address, and complete credit card information, or your bank account information, to process your payments to us for the WhoEasy Service as set forth in our Terms. Our payment processing service provider will retain this information, in accordance with this Privacy Policy and any service agreement entered into between our payment processor and us.
Information Collected Through Communication with Us
If you provide us Feedback or communicate with us by e-mail, online forms, or surveys, any information provided in such communication may be collected as Personal Information. Any Feedback you provide will be governed by the Terms.
We may use Personal Information submitted in your communications to contact and respond to you and otherwise in the same manner as described above for registration information.
Information You Provide Publicly
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the WhoEasy Service, or transmitted to other users of the WhoEasy Service or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the WhoEasy Service with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Log File Information
When you register an account with or access the WhoEasy Service, our service provider may collect, and share with us, information such as your web request, IP address, browser type, domain names, access times, and other browsing information.
This information is used to provide you the WhoEasy Service and other services requested by you, improve the WhoEasy Service and other services provided to you by us, and customize the content and layout for each individual user.
Cookies and Web Beacons
Cookies and web beacons are very small text files that are stored on your computer when you visit certain web pages. We collect information through cookies and web beacons about your web browsing activities such as the address of the page you are visiting, the address of the referrer page you previously visited, the time you are viewing the page, your browsing environment and your display settings. We use cookies and web beacons in connection with the WhoEasy Service for some of the following purposes:
Anonymous Information
We may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you. We may use Anonymous Information at our discretion and for any purpose. When we provide or use this information, we employ procedures so that the data does not identify you and we contractually prohibit recipients of the data from manipulating the data in a way that would re-identify it back to you.
Other
We may provide certain additional services and/or communications if you select such additional services and/or communications by opting-in to such additional services and/or communications using the procedures set forth in connection with such additional services and/or communications. We will collect your name, e-mail address and telephone number (if provided) and any other information we specify in the user interface of our services where you opt-in by clicking on such buttons. We may use such Personal Information to send you the corresponding additional services and/or communications.
Third Party Tracking Tools
We may also share anonymous browsing data with advertisers and other third parties who may use it for advertising purposes, including for the purpose of serving targeted advertising on our behalf on non-affiliated third party websites. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information we or the online advertising network serving the ad collect about your online activities here and elsewhere over time. For example, anonymous information collected across multiple websites, including without limitation our Website, that you visit over time may enable the ad network to predict your preferences and show you ads that are most likely to be of interest to you.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of these types of ads and for general information about the Network Advertising Initiative, please visit the NAI website, available at http://www.networkadvertising.org.
Please note that we do not share any information that identifies you personally with the third party service providers who serve ads on our behalf. When we provide or use Anonymous Information, or anonymous browsing data, we employ procedures so that the data does not identify you and we contractually prohibit recipients of the data from manipulating the data in a way that would re-identify it back to you.
When you browse or access the WhoEasy Service, we may use trusted third-party tools to analyze website usage, monitor performance, and prevent fraud, an example of which includes Google Authentication. We may use these tools regardless of whether or not you enable the Do Not Track setting in your browser. Fraud prevention tools may collect Personal Information regardless of whether or not you enable the Do Not Track setting in your browser; however, the Personal Information collected or included in connection with fraud prevention data is used specifically for fraud and abuse prevention and will never be used for marketing purposes.
For more information regarding "Do Not track" please see Section 6 titled "Your Choices and Rights."
Affiliates
To provide the WhoEasy Service and various services to you, we may use the efforts of our parent company, and any subsidiaries, joint ventures, or other companies, existing or formed in the future, under a common control (collectively, "Affiliates"). We may share some or all of your Personal Information with our Affiliates in which case we will require our Affiliates to comply with this Privacy Policy.
Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event we are acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as a part of such merger, acquisition, sale, or other change of control. In an event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors’ rights generally, your Personal Information may be transferred by the trustee. If we, or any of our Affiliates, are acquired by or merged with a third party, that third party will possess the Personal Information in our, or our Affiliate’s, possession and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
Other Disclosures
Regardless of any choices you make regarding your Personal Information (as set forth below), we may disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful requests or legal process, (ii) to establish or exercise our legal rights or defend against legal claims or protect other users, (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law, or (iv) to investigate, prevent, or take action regarding any violation of this Privacy Policy or the Terms.
6. YOUR CHOICES AND RIGHTS
Changes and Deletion of your Data
If your Personal Information changes, or if you no longer desire to use or access the WhoEasy Service, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, or by contacting us at contact@whoeasy.com. We will retain your information for as long as your account is active or as needed to provide you services. Please note that even if you have asked us to delete your account or any associated data as described above, we may be required to keep certain of your information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. In any event, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Opting Out
We will periodically send you free newsletters and e-mails that directly promote the use of our WhoEasy Service or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails and you will have the opportunity to "opt-out" by following the unsubscribe instructions included in these emails or you can contact us at contact@whoeasy.com.
Services-Related Communications
While you may "opt-out" of certain services-related communications by following the unsubscribe instructions provided in the e-mail you receive or by contacting us at contact@whoeasy.com, you may not, despite your indicated e-mail preferences, "opt-out" of other services-related communications regarding your account or any payments made, or to be collected, by you, including receiving notices of any updates to our Terms or this Privacy Policy, except by terminating your account.
Do Not Track
Do Not Track is a standard that is currently under development and not yet finalized. As such we adhere to the standards set out in this Privacy Policy. To learn more about Do Not Track please visit All About DNT.
7. COMPLIANCE NOTICES, CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION
We maintain a procedure in order to help you confirm that your Personal Information remains correct and up-to-date. At any time, you may contact us via email: contact@whoeasy.com to update your Personal Information. In the case that your credit card, user name, or password is lost, stolen, or used without permission, promptly contact us at contact@whoeasy.com to update the Personal Information we have on file for you.
Except as otherwise set forth herein, we do not share your Personal Information with third parties for their own use without your permission.
We employ technical and administrative control and maintain the security of information collected through the WhoEasy Service. Although we follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive, no method of transmission over the Internet, or method of electronic storage, is 100% secure and no company, including us, can completely or effectively eliminate the risks connected to handling information on the Internet. You acknowledge and agree that you provide your Personal Information at your own risk. If you have any questions regarding our security measures please contact contact@whoeasy.com.
8. CHILDREN’S ONLINE PRIVACY PROTECTION ACT
We comply with the Children’s Online Privacy Protection Act (COPPA) where it applies to our information collection practices. We do not actively or knowingly collect or maintain Personal Information from or about children under the age of thirteen (13) and the WhoEasy Service is not intended to be used by persons under thirteen (13). If you are under the age of thirteen (13), please do not use the WhoEasy Service at any time nor in any manner. If we discover that we have collected Personal Information on a child under the age of thirteen (13) without proper consent, we will promptly remove that information from our systems and we may deactivate the associated account. If you find that we have personal information about anyone below thirteen (13) years of age, please inform us at contact@whoeasy.com.
9. THIRD PARTY WEBSITES
Please be aware that the terms of our Privacy Policy do not apply to third party websites, products, services, or content or to links provided for the foregoing on the WhoEasy Service. Third party providers of such third party websites, products, services, or content, may collect (via tracking technologies like cookies or web beacons) and use anonymous information regarding your interaction with the third party website, product, service, or content that they deliver and with which you interact. We are not responsible for the privacy practices or the content of such third party websites.
10. UPDATES AND CHANGES TO PRIVACY POLICY
We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy to reflect changes to our information collection practices, simply by posting such change, update, or modification to the Website and without any other notice to you. If we make material changes to this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Website or through the WhoEasy Service or notifying you at the email you designated upon registration of your account. Any such change, update, or modification will be effective immediately upon posting on the Website. Your continued use of the WhoEasy Service after such notification of changes as described above will constitute your agreement to such changes. We encourage you to periodically review this page for the latest information on our privacy practices. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the WhoEasy Service.
11. QUESTIONS AND ADDITIONAL INFORMATION
If you have questions about this Privacy Policy or want to contact us, please send an email to contact@whoeasy.com.
These WhoEasy Terms of Service (the "Service Terms" or "Terms") and other policies incorporated by reference in these Terms, including our Privacy Policy form a legally binding agreement between R E Y A LLC ("WhoEasy", "we", "our" or "us"), who owns and controls the website www.whoeasy.com (the "Website"), and you, the user of the Services, as such term is defined below, ("you", "your", "yours" or "User"), and describe the terms under which you agree to use the products and services on www.whoeasy.com, any successor website and any other service or product which may be made available to you by us for which you have enrolled or registered or have been enrolled or registered by an authorized third party (collectively the "Services" and individually a "Service").
PLEASE NOTE, THESE TERMS ALSO CONTAIN AN AGREEMENT TO ARBITRATE IN SECTION 17 BELOW WHICH WILL REQUIRE YOU TO SUBMIT CLAIMS YOU HAVE AGAINST US TO BINDING AND FINAL ARBITRATION.
IF YOU DO NOT AGREE TO ALL OF THESE TERMS AND CONDITIONS OF THESE TERMS, OR IF YOU DO NOT HAVE ELIGIBILITY TO ENTER INTO THESE TERMS AS SET FORTH IN SECTION 1.2 BELOW, DO NOT CREATE AN ACCOUNT, DO NOT USE THE SERVICES, OR VISIT THE WEBSITE. IF YOU ARE A COMPETITOR OF WHOEASY YOU MAY NOT ACCESS OR USE THE SERVICES WITHOUT WHOEASY’S PRIOR WRITTEN CONSENT.
Email: contact@whoeasy.com
Subject Line: "Attn: Legal"
The notice must include your name, mailing address, and phone number (if any), and must describe the nature and basis of the claim or dispute, as well as set forth the specific relief sought. If a dispute is not resolved within 60 days of after we receive your notice, either you or we may bring a formal arbitration proceeding with the American Arbitration Association ("AAA").