natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any personal information are, or are to be, processed.
1. Children’s Privacy
Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions). Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.
2. Information Provided Directly By You
We collect information you provide directly to us, such as when you request information, create or modify your WEBCBG account, request Services, order a subscription to our Services, complete a WEBCBG form, contact customer support, or otherwise communicate with us in any manner. This information may include, without limitation: name, e-mail address, physical address, business address, business title, phone number, or any other personal information you choose to provide.
3. Information Collected Through Your Use of Our Services
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in) and how you interact with other users and us. The following are situations in which you may provide Your Information to us:
• When you fill out forms or fields through our Services.
• When you create a subscription for our Services.
• When you upload to WEBCBG information regarding properties that you own.
• When you answer questions on a questionnaire.
• When you communicate with us or request information about us or our products or Services, whether via email or other means.
• We may collect your IP address. This information is used to enable us better understand how our
Services are being used and allows us to administer and customize the Services to improve your overall experience.
4. Information Collected From Other Sources We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your WEBCBG account with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Website or App. This includes, without limitation, profile information, profile picture, gender, username, language, country, e-mail addresses, phone numbers.
5. Aggregated Data We may collect, use, and share Aggregated Data such as statistical data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data as this data does not directly or indirectly reveal your identity.
6. Cookies, Log Files and Anonymous Identifiers
6.1 When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
6.2 Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Website.
6.3 Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
6.4 We may also employ Cookies so that we remember your computer when it is used to return to the Website to help customize your WEBCBG web experience. We may associate personal information with a Cookie file in those instances.
preferences, understand when you are interacting with our Services, and compile other information
regarding use of our Services.
6.6 WEBCBG may use third-party services such as Google Analytics to help understand use of the Services.
These services typically collect the information sent by your browser as part of a web page request, ncluding Cookies and your IP address. They receive this information and their use of it is governed by
their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager.
7. Device Information
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
8. Location Information
When you use the Services, we may collect your precise location data. We may also derive your approximate location from your IP address.
9. Call and SMS Data
In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection, and storage of this information.
10. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and
text transmissions. The GDPR and certain jurisdictional laws may not allow the exclusion or limitation of certain liability for data security. If these laws apply to you, some or all the above limitations may not apply to you. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
11. The Legal Basis and Reasons For Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:
11.2 It is necessary for entering into, or performing, the obligations of a contract between you and WEBCBG, including, without limitation, the Terms of Service agreement which may be accessed by you here and any subscription for our Services that you order;
11.3 It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in.
11.4 It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;
11.5 To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.
11.6 To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages.
11.7 To send promotional communications that you have consented to receive or have expressed a legitimate interest in receiving.
11.8 It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you.
11.9 It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
12. How We Use Information We Collect Our primary purpose in collecting, storing, using, and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease, or barter your information to anyone unless you grant us explicit permission for this information to be shared.
12.1 We will use this information to:
(i) Operate and provide our Services.
(ii) Improve our internal operations, systems, products, and Services.
(iii) Provide users with customer support including, sending you related information, including
confirmations, invoices, technical notices, updates, security alerts, and administrative messages.
(iv) Understand you and your preferences to enhance your experience and enjoyment using our
(v) Analyze, improve, and manage our Services and operations.
(vi) Contact you for administrative, account and promotional purposes.
(vii) Resolve problems and disputes and engage in other legal and security matters.Protect,
investigate, and deter fraudulent, unauthorized, or illegal activity.
12.2 Additionally, we may use the information we collect about you to:
(i) Send you communications we think will be of interest to you, including information about products,
services, promotions, news, and events of WEBCBG and other companies, where permissible and
according to local applicable laws.
(ii) Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity
including, without limitation, infringement of intellectual property rights of third parties.
13. How We Share Information We Collect
the time of collection or sharing, including as follows:
(i) With our third-party Service Providers to enable them to provide the Services you request.
(ii) With third parties with whom you choose to let us share information, for example other websites
or apps that integrate with our API or Services, or those with an API or Service with which we
(iii) In response to a request for information by a competent authority if we believe disclosure is in
accordance with, or is otherwise required by, any applicable law, regulation, a judicial
proceeding, court order or legal process.
(iv) With law enforcement officials, government authorities, or other third parties if we believe your
actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the
rights, property, or safety of WEBCBG or others.
(v) In connection with, or during negotiations of, any merger, sale of company assets, consolidation
or restructuring, financing, or acquisition of all or a portion of our business by or into another
(vi) If we otherwise notify you and you consent to the sharing;
(vii) In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We
only use such data in the aggregate form and our analytical services do not record any personal
13.2 We may disclose Your Information:
(i) To any person who, in our reasonable judgment, is authorized to receive Your Information as
your agent, including as a result of your business dealings with that person (for example, your
(ii) To our third-party vendors and service providers so that they may provide support for our internal
and business operations, handling of data processing, data verification, data storage and our
Services maintenance and security. These companies are authorized to use Your Information
only as necessary to provide these services to us and are contractually obligated to keep Your
(iii) As we deem necessary, in our sole discretion, if we believe that you are violating any applicable
law, rule or regulation, or are otherwise interfering with another’s rights or property, including,
without limitation, our rights or property.
(iv) If requested by authorities in the event of any act of terrorism or instance of local, regional or
(v) To enforce or protect our legal rights.
14. Sharing Information With Law Enforcement
14.1 WEBCBG is committed to cooperating with law enforcement while respecting everyone’s right to privacy.
If WEBCBG receives a request for user account information from a government agency investigating
criminal activity, we will review the request to be certain that it satisfies all legal requirements before
releasing information to the requesting agency.
14.2 Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer
Communications or Records), WEBCBG may disclose user account information to law enforcement,
without a subpoena, court order, or search warrant, in response to a valid emergency when we believe
that doing so is necessary to prevent death or serious physical harm to someone. WEBCBG will not release more information than it prudently believes is necessary to prevent harm in an emergency.
16. Do Not Track Settings
Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a “do not track” feature enabled may still accept Cookies. There currently is no accepted standard for how to respond to this signal, and we do not take any action in response to this signal.
the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.
18. Account Information
You may correct your account information at any time by logging into your online account. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud, we may seek to resolve the issue before deleting your information.
18.1 Your Access and Rights to Your Personal Information
18.2 The GDPR provides you with certain specific rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
18.4 Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
18.5 Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
18.6 Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
18.7 Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable, and commonly used format.
To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
18.8 Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
18.9 Right to Complain. If you are based in the EU, you can file a complaint with the supervisory authority in your Member State. By way of example, if you reside in the United Kingdom you can file a complaint with the Information Commissioner’s Office here.
19. Your California Privacy Rights
19.1 California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year.
19.2 If you are a California resident and would like to make such a request, please submit your request in writing to: email@example.com
20. Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your
account is active or as needed to provide you services. Following termination or deactivation of your account, we
will retain information for at least 1 year and may retain the information for as long as needed for our business
and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer
retention period is required by law (for example for regulatory purposes).
21. Contact Us If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Our office address: 575, Lexington Avenue, New York, NY 10022 – USA