9.1. Updates to this Privacy Policy. We update this Privacy Policy when necessary or appropriate to provide greater transparency or in response to
- feedback from customers, regulators, and others,
- changes to our Services,
- changes in technology,
- changes in our business, or
- changes in our data processing activities or policies.
When we modify this Privacy Policy, we will give you notice by posting the amended Privacy Policy on one or more of the Pragmatic Websites and, if the changes meaningfully affect your rights, by e-mail (if your e-mail address is included in your Pragmatic User Account). The amended Privacy Policy will include an effective date, and it will be effective on that date. We encourage you to periodically review this Privacy Policy to understand how we are protecting your information.
9.2. Payment Information and Processing. We may, from time to time, use one or more third party payment processors to process payments made in connection with the Pragmatic Services, and we may share or transmit your Financial Data to our payment processors. You acknowledge and agree that the processing of payments is subject to the terms and privacy policies of our payment processors and that we are not responsible for enforcing them.
9.3. Children Under Age 13. We are committed to protecting the privacy of children under the age of thirteen (13) years (each a “Child” and collectively, “Children”). Access to and use of the Pragmatic Services by Children is prohibited. The Pragmatic Services are not designed for or marketed to Children, and we do not knowingly collect personal information from Children. If we learn we have collected or received personal information from a Child, we will delete that information. If you believe we might have any information from or about a Child, please contact us.
9.4. Third Party Sites. Our Services may contain links to other websites that are operated by third parties, including the websites of our other users, customers, or service providers. Once you have clicked on a link connecting you to such third-party website, you will leave our Services and be taken to a website that we do not control. This Privacy Policy does not apply to any personal information (or other information) collected on a third-party site. We suggest you read the privacy policy of the third-party site before providing any personal information on such third-party site. We are not responsible for any use by any person or entity of any information that you may provide while accessing or using any websites or services provided by a third party.
9.5. Do Not Track Policy. California law requires that operators of websites and online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signal. You do have the option to opt-out in accordance with the provisions of 6.2 above.
9.7. Use of Non-Personal Information. As used in this Privacy Policy, “Non-Personal Information” means information or content other than personal information, including, for example, aggregated, generalized, anonymized, or de-identified information about our users and other information that does not identify any individual. We may use Non-Personal Information (including, for example, aggregated information about our users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and we may share Non-Personal Information with others, including our partners, affiliates, and our service providers.
9.7.1. Google Analytics. We may, from time to time, use a tool called “Google Analytics” (including Google Analytics Demographics and Interest Reporting features) to collect information about your use of our Services, which helps us provide content that is relevant to you and optimized for the devices that you use (such as smartphones and tablets). We respect and value your privacy, and we never combine the information collected through the use of Google Analytics with your personal information. We use the information we receive from Google Analytics only to improve our Services and our content and marketing. Google’s use and sharing of information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (http://www.google.com/analytics/tos.html) and the Google Privacy Policy (http://www.google.com/privacypolicy.html). For more information, see “How Google uses data when you use our partners’ sites or apps” at www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings (https://www.google.com/settings/ads) tool. As an added privacy measure, you can use the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout/).
9.8. Our retention of personal information. We retain personal data for as long as necessary to provide our Services and fulfill the transactions you have requested, or for other legitimate purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different types of information, the context of your use of our Services or our other interactions with you, the actual retention periods can vary significantly. After the applicable retention period, we will either delete or anonymize your personal information or, if that is not reasonably feasible (for example, because the information has been stored in a backup archive), then we will securely store your personal information and isolate it from any further use. If we anonymize your personal data (so that it can no longer be associated with you), we may use that information indefinitely without further notice to you.
- Account information. We retain the information associated with your Pragmatic User Account until your Pragmatic User Account is closed. After your Pragmatic User Account is closed, we will retain some of your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Employer/Organization Established User Accounts. If you access or use our Services through an account established by an employer or organization, we will retain your personal information as long as required by the administrator of your employer/organizational account.
- Marketing information. If you have chosen to receive marketing communications from us, we retain your Contact Data and your marketing preferences unless you specifically ask us to delete such information.
9.8.1. Personal information in backups. After personal data is deleted or anonymized in our production (primary) systems, copies of the personal data may remain in our backups for a limited period of time until it is overwritten, replaced with subsequent backups, or otherwise deleted pursuant to our backup retention schedule. Personal data that was previously deleted or anonymized based on your request or the expiration of the applicable retention periods, but which remains in our backups, will be put beyond use, and we will:
- not use the personal data to inform any decision in respect of any individual or in a manner that affects the individual in any way;
- not give any other organization access to the personal data (or, in the case of a service provider hosting a backup on our behalf, we will ensure that the service provider is prohibited from accessing the personal data);
- protect the personal data with appropriate technical and organizational security measures; and
- permanently delete the personal data in accordance with our backup retention schedule.
If we ever access or restore data from our backups, we will take appropriate technical and organizational measures to ensure that personal data that was previously deleted or anonymized pursuant to your request is not processed again after the restoration and is promptly deleted or anonymized again.
9.9. Security. We have implemented appropriate security measures so safeguard your personal data from accidental loss or deletion and from unauthorized access, use, alteration, and disclosure. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to access that information. We require all such persons to process your personal data only pursuant to our instructions, and all such persons are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable governmental authority of a breach when we legally required to do so. The safety and security of your information also depends on you. You are responsible for safeguarding your Login Credentials associated with your Pragmatic User Account and notifying us immediately if you suspect your Login Credentials for your Pragmatic User Account have been compromised. We urge you to be careful about giving out information in public areas of the Pragmatic Services. The information you share in public areas may be accessed by any of our users. You are strongly cautioned to never share sensitive information with other users through the Pragmatic Services.