Last Update: 12.12.2020
We may collect and process the following data about you:
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at email@example.com. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law.
If you sign up to receive promotional materials from us via email and/or (push notifications), we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at firstname.lastname@example.org, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level.
If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply.
Pivony and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don’t have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don’t need to do it for every web page requested, and to measure how people are using the Products.
We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third-party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third-party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.
We use third party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.
We will acquire consent from you in order to use such trackers to the extent required by applicable law.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
As true of most websites, we gather certain data and automatically and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
All data you provide to us through the Products is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and suggest that your change your password frequently. Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
There is interest by large consumer communities (companies, universities, hospitals, government agencies, etc.) (“Communities”) to introduce the Products to their employees and members. If you have registered to use the Products through a code or other registration credential furnished by a Community (a “Community Subscription”), the Community will have access to your email address, the date you registered to use the Products, and the date on which you last used the Products. The Community will also have access to your Community’s aggregated and anonymized general usage data. Your Community may also have access to your usage data on an individual basis, but only if you have provided appropriate consent under applicable law for such sharing.
You may be able to log-in to our Products using sign-in services such as Google Sign-In, Facebook Connect. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Google Sign-In give you to the option to post data about your activities on our Products or to your profile page to share with others within your network.
As you may know, a recent European Union law called the General Data Protection Regulation (“GDPR”) and Republic of Turkey’s Law On Personal Data Protection (“KVKK”) give certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom exercise those rights. As required under applicable law, the rights afforded to you are:
A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “My Data” tab in the Products.
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Pivony will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Pivony may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to Pivony, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Pivony. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Pivony. Pivony may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your Pivony account and following the instructions here.
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Pivony’s personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Pivony instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com.
You may access your personal data to modify or update at any time via an online account, or by emailing firstname.lastname@example.org. We will respond to your request in a reasonable timeframe in accordance with applicable law.
We use information held about you in the following ways:
In accordance with GDPR and KVKK, Pivony provides the following information regarding legal bases for personal data processing:
The performance of the contract (the Pivony Terms & Conditions) between you and Pivony for the data processing relating to your use of Pivony’s Products;
Pivony’s legitimate interest, more specifically:
We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also disclose your personal data to third parties as follows:
The retention periods applied by Pivony comply with applicable legislation in effect on the date hereof, namely:
Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing email@example.com.
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
Our Products include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button, or interactive mini programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person’s account.
The subsidiaries, service providers or other third parties listed above to whom Pivony may disclose your personal data may be domiciled abroad, and in particular outside the United States of America, European Union, Switzerland, United Kingdom or Republic Of Turkey.
In such case, Pivony will require them to take, in accordance with applicable legislation, all organizational and technical measures that permit ensuring an adequate level of protection of your personal data, such the use of Standard Contractual Clauses approved by the European Commission.
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