Consumer Services Privacy Policy

Carizma Consumer Services Privacy Policy 2022

Carizma knows that you take your privacy seriously. We do, too. We seek to be transparent about our data practices and give you control over the information we collect about you. This Consumer Services Privacy Policy covers Carizma Inc. and its affiliates and subsidiaries.

 

The Consumer Services include our websites (the “Sites”), our mobile applications (the “Apps”), and other online services that we own or control (collectively, the “Consumer Services”). This Privacy Policy does not apply to our Enterprise Services or information related to our enterprise customers, business partners or data suppliers. Please see our Enterprise Services Privacy Policy for details about our information practices related to those business services.

This Policy also describes applicable data protection rights including a right to object to some of our processing.

To read our entire policy, see below.

  1. What Data Does Carizma Collect

Data you provide us:

We collect data that you provide to us when you create an account, such as full name, email address, phone number, birthday, gender, the city in which you created your account, and, where applicable, your social media username and other data if you create an account using third party log-in credentials (please see “Data Received from Third Parties” below).

We may also collect other data you provide when you use the Consumer Services, including pictures you upload, messages you send through the Apps, searches, likes, follows, check-ins, tips, survey responses, demographic information, and any other data that you voluntarily provide to us.

Data Collected Automatically When You Use Our Consumer Services:

If you opt in to sharing your location with us, we automatically receive data about your precise location (e.g., latitude-longitude coordinates) whenever you use the Consumer Services (e.g., open our mobile apps, visit our website, etc.). If you opt in to have background location on in our Apps, we will collect data about your location when you are not using the Apps and when the Apps are closed (as permitted by your device settings).

We also collect additional data about you when you use the Consumer Services. For example:

  • data about how you interact with the Consumer Services, such as your search words, page views, date and time of interactions, time spent on each page, or posts you make.
  • device information, such as your hardware model, operating system and version, unique ID and device data such as device identifiers, IP address, sensor data, browser type, language, and wireless network, mobile device name, types of mobile apps installed; and
  • data from cookies, pixels and other technologies, such as cookie ID, advertising ID or other unique advertising ID, web beacons, and local storage. You can control certain types of cookies through your browser settings or other tools. 

 

Data received from third parties

We may receive data about you from third parties, including: 

  • our Enterprise Customers (e.g., business customers of our Products)
  • third parties that provide services to us, such as unaffiliated apps and websites, offered by our business partners, including those from whom we license data.

The information we obtain from third parties includes demographic data, data about how you interact with the third party’s websites, apps and smart TVs and streaming devices, device data (including mobile device and advertising identifiers, such as Apple IDFA or Google Advertising ID), and information from cookies, pixels and other similar technologies. If we obtain data about you from our Enterprise Customers and third parties, we will combine all data collected about you into one single profile.

  1. How is my data used by Carizma?

To Operate, Maintain and Improve the Consumer Services

We use your data to operate, maintain the Consumer Services, and our business, and to understand you better and personalize the Consumer Services. To do so, when you download more than one App, we combine your data that we obtain in each App. In addition, if you use the Consumer Services when you are not logged into your Carizma account, when you subsequently log in to your Carizma account, we combine data collected while you were not logged in.

Some features and functionality in our Apps require that you provide your location. If you have location services turned on, whenever you use our Apps on your mobile device, we collect and use your geocoordinates (e.g., latitude and longitude) to tailor the Consumer Services to your current location. We will only process your location with your express permission. If you have persistent background location turned on, we will obtain your device’s location even if you are not using the Apps. Your location is never shared with others, except with your consent or as permitted under this Privacy Policy.

We use various technologies to determine your precise location, such as the location services of your operating system or browser, sensor data from your device (e.g., magnetometer, barometer, gyroscopes, accelerometers, compasses, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other data that may help us understand your precise location.

If you have opted-in to sharing your background location with us in our Apps, you may remove your permission at any time by going into your operating device settings and toggling off background sharing.

We also use your data to improve the Consumer Services and our business, conduct research and development, perform analytics, develop, and offer new products and service, and to infer certain details about you, including details about you, your interests and whether separate devices (e.g., mobile phones, tablets, and/or TVs) are owned by you or by members of your household. For example, we may customize the Consumer Services to allow you to add friends from your device’s contact list who are also using the Consumer Services or, if applicable, your Facebook, Google, or Twitter account, if you have opted to connect these accounts to your Carizma accounts). We do not store your contact lists. As another example, we also use your data to help us map locations (as defined below). For example, we may use device signals to determine that a particular device is within a particular venue. Additionally, if you consent to sharing crash data (when the Apps crash) with us, we may use that data to help us analyze the cause of the crash and improve the Consumer Services.

Communicate with you

We use your data to communicate with you by email, text (if you opt-in), or in our Apps, about new product offerings, updates to the Consumer Services, or anything else we think may be of interest to you. To opt out of receiving marketing communications, please see the “Unsubscribe from Marketing Emails and Text Messages” section of this Privacy Policy below.

Rewards, contests and sweepstakes

We may use your data, including your completed surveys, to enable you to earn points and administer your participation in contests and sweepstakes. If you enter a sweepstakes, we will use certain information associated with your account, such as your name and email address, to run the sweepstakes and fulfill prizes to you.

Protection of our rights

We may use your data to protect the rights, property or safety of Carizma, the Consumer Services, our users, and employees, or any third party. For example, we may use your data to protect against identity theft, prevent fraud or other criminal activity, claims or other liabilities. We may also use your data to comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Privacy Policy and our Terms of Service.

Our Products

We use your data in our business products and services (“Products”) that we offer to our partners. We receive data from unaffiliated apps, websites, smart TV providers, online advertising services, and our partners, which we may use to send you advertisements that are tailored to your interests or to measure whether an ad that you were exposed to resulted in a visit to a physical store. The data collected for this purpose includes data about how you interact with the Consumer Services or with unaffiliated websites, and apps, device data, and data from cookies, pixels, or other similar technologies.

We combine the data described above with demographic data, location and other interest-based segment data obtained from third parties, including data obtained from the Enterprise Services to provide our Products.

  1. When is my data shared?

We may share certain data about you as further described in this Consumer Services Privacy Policy or when you have given us consent to do so.

Data that may be shared with other users

When you use the Carizma Apps and Sites, your authorized friends may see some of your data (e.g., name, profile photo, hometown, users you are following, your followers, and other information you post). When you communicate using the Carizma Apps and Sites, such as when you direct message your friends or check-in to a store, restaurant, or a location (each a “Location”), your friends may see this data. You can always control what you want visible to others, including your friends, in your “Settings”.

Publicly available data includes your public profile, tips, likes, saves, photos, lists you create and follow, badges/stickers, mayorships, and lists of followers. Public data may be searchable by search engines and be shared with third parties, including through our Products.

Data that may be shared with affiliates, service providers and partners

We may share your data with our affiliated entities, and service providers that perform services on our behalf, such as cloud storage, IT services, marketing, analytics and search engine and other software services. These service providers may be located in countries other than the country in which the information originally was collected, such as the United States and Canada. We do not authorize our service providers to retain, use or disclose the data except as necessary to perform services on our behalf or comply with legal requirements.

In addition, when we partner with a business, we may share your mobile advertising identifier or another identifier, and other data such as inferred visits to public locations (such as a store or a restaurant) or as a part of a chain of inferred visits (such as this device went to John’s Coffee Store, then Sarah’s Yoga Studio, and then after, Jenny’s Juice Bar). We do not share your latitude and longitude coordinates, and we do not share inferred home and work location. Data is only shared after it has been processed into an inferred visit to a public location. We may also assist our business partners in combining the data we obtain when you use the Consumer Services with the data we receive from those business partners about online or offline advertisements that you may have viewed (including on unaffiliated apps, websites, and billboards). We do this so that our partners can serve targeted ads, measure the effectiveness of their ad campaign, perform analytics and/or understand you better based on preferences that we infer about you. We may also share data to our developer community or third parties for analytical or other purposes.

Data that may be shared with our affiliates and subsidiaries

We may share data with our affiliates and subsidiaries in order to improve the Consumer Services, develop and offer our Products, and for other purposes.

Compliance with law, protection of rights and corporate events

We may share data (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (v) in connection with an investigation of suspected or actual illegal activity; or (vi) to protect the rights, property, or safety of Carizma and our products and services, our employees, or users and others.

We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.

When you consent

We will also share your data with your consent.

  1. What about cookies and similar technologies?

We may use technologies like cookies, pixels, web beacons, local storage, and other automated technologies on our Sites, in our emails, within our Apps, and sometimes in third party apps that use our APIs or SDKs to provide you with a range of products and services. We use these technologies for a number of purposes, such as for authentication, security, preference settings, in our Products for advertising, measurement and analytics.

You can control cookies through your browser settings and other tools. If you reject cookies, this could affect the availability and functionality of the Consumer Services. For more information, including the types of cookies and similar technologies found on Carizma.

Third-Party analytics

On our Consumer Services, we use third-party analytics services, such as those of Google Analytics. The service providers that administer these analytics services use cookies and other automated technologies to collect data (such as IP addresses and other device identifiers) to evaluate, for example, use of our Consumer Services and to diagnose technical issues. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

Interest-based advertising

Through our Consumer Services, both we and certain third parties (such as our business partners) may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. You may see our ads on other websites or mobile apps because we use third-party ad services. Through such ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track users’ online activities over time and across multiple online services by collecting information through automated means, including through the use cookies, web server logs, web beacons, device identifiers and other similar technologies. The ad services use this information to show ads that may be tailored to users’ interests. The information ad services may collect includes data about users’ visits to our Consumer Services and other websites and apps that participate in the relevant ad services, such as the pages or ads viewed, and the actions taken on the websites or apps. This data collection takes place both on our Consumer Services and on unaffiliated third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

To learn how to opt out of interest-based advertising, please visit the “U.S. Opt Out” section of this Privacy Policy.

  1. How do I access or delete my data?

You may access and update your data at any time through the “Settings” tab in your Carizma account. To view every place that you have visited, you may access this data in your profile within Carizma.

You may delete your data and account at any time by clicking on “forget me”” link in your “Settings”. If you delete your data, your profile, including your check-in history, tips and photos, badges and stickers received will be removed from the Consumer Services, and you will no longer be able to access such data. We will not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your personal information or posts may remain on backup media for a short period of time thereafter.

If you wish to delete your Placed account, you can do so by requesting an account deletion from the in-app “Contact Us” form or sending an email to support@Carizma.com.

We may also retain data as required by applicable law and we may retain data that has been anonymized or otherwise does not constitute or contain personal information.

If you have questions about accessing, updating, or deleting your data, please email support@Carizma.com

If you are from the EEA, UK or Switzerland, you may also have additional rights, which are summarized under “More Information for Consumers from the EEA, UK or Switzerland” below.

If you are a California resident, please refer to the “California Residents” section of this Privacy Policy for information about your privacy rights, including the right to access and delete your personal information.

  1. Unsubscribe from marketing emails and text messages
  • By Email:You can opt out of marketing or promotional emails at any time by adjusting your preferences in your “Settings” in the App. You may also unsubscribe from marketing emails by following the instructions in the email. Please note that you cannot opt out of service or legal notices.
  1. Personal information retention

To the extent permitted by applicable law, we keep the personal information you provide for the purposes indicated in this Privacy Policy for the duration of our relationship, plus a period of up to three (3) years, unless we retain the information longer for our legitimate business purposes or to comply with the applicable statute of limitations periods and other applicable laws or legal considerations.

  1. How Carizma protect personal information

We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Consumer Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

  1. Children under 15

Our Consumer Services are intended for a general audience and are not directed at children. We do not knowingly collect personal information online from individuals under the age of 13 or such other age as may be directed by applicable law.

  1. U.S. Consumer Rights and Disclosures

U.S. Opt Out

In the United States, the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) have established rules about interest-based advertising including cross-device linking for such advertising. Interest based advertising is a digital advertising that is tailored to a consumer’s inferred interests, preferences, and locations. Cross-device linking is the practice of associating different browsers and/or devices (such as mobile devices and televisions) based on information about the likely relationships among them.

Carizma is a member of the NAI and adheres to the NAI Code of Conduct as described on the NAI website. We adhere to the DAA Self-Regulatory Principles as described on the DAA website. At this time, we do not honor web browser Do Not Track (“DNT”) signals or other similar mechanisms. In addition, we may use or transfer data for interest-based advertising, including cross-device linking.

You may opt out of seeing interest-based ads from us or our third party advertising partners on your desktop browser and/or mobile web browser by visiting the DAA at http://www.aboutads.info/choices/ or by visiting the Network Advertising Initiative (“NAI”) at http://www.networkadvertising.org/choices/. You may also opt out of seeing interest-based ads on TV streaming devices and smart TVs by visiting the NAI’s opt out for these devices at https://www.networkadvertising.org/internet-connected-tv-choices/). You may opt out of seeing interest-based ads and ad delivery/reporting by downloading the DAA’s AppChoices mobile application, which is available here:

  • DAA AppChoices iOS
  • DAA AppChoices Android
  • DAA AppChoices Amazon

 

When you opt out on a particular device, we will stop using and transferring mobile app data from that device for interest-based advertising on, and ad delivery/reporting to, other linked devices. Additionally, we will also stop using mobile app data coming from other linked devices for interest-based advertising on, and ad delivery/reporting to, the device from which the choice was exercised. If you use more than one device, you should opt out on each device. Certain versions of your device’s operating system permit you to opt out of interest-based advertising. Please visit your device settings to limit such tracking.

Please note that when you opt out of interest-based ads, you will still see ads, but they will no longer be based on your interests or behavior. In addition, we may also continue to collect, use and transfer mobile app data for purposes other than interest-based advertising and ad delivery/reporting, as described in the “How Is My Data Used By Carizma” section of this Privacy Policy.

If you are a California resident, for more information about your privacy rights, please see the section of this Privacy Policy below titled “California Residents”.

How to Opt-Out of advertising services by Carizma’s Enterprise Customers and Data Suppliers

To opt out of interest-based advertising by Carizma’s Enterprise Customers and data suppliers that participate in the NAI or the DAA, visit NAI’s opt out page or the DAA’s consumer choices page.

U.S. Segments Disclosure

The NAI requires members to disclose standard interest segments based on health- and wellness-related interests and information, or based on political information or interests, that are used to deliver interest-based advertisements in the United States.

  1. California Residents

CALIFORNIA CONSUMER PRIVACY STATEMENT

This California Consumer Privacy Statement (“Statement”) It applies solely to California consumers that use or interact with our Consumer Services.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

  1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

  • Identifiers:identifiers such as a real name, alias, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers,
  • Additional Data Subject to Cal. Civ. Code § 1798.80:physical characteristics or description and education,
  • Protected Classifications:characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender identity, gender expression, sexual orientation, and marital status,
  • Commercial Information:commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies,
  • Online Activity:Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements,
  • Geolocation Data,
  • Sensory Information:electronic, visual, and similar information,
  • Employment Information:professional or employment-related information, and
  • Inferences:inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in our Consumer Services Privacy Policy and for the following business purposes specified in the CCPA:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services,
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance,
  • Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction,
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity,
  • Debugging to identify and repair errors that impair existing intended functionality,
  • Undertaking internal research for technological development and demonstration, and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
  1. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

  • Our affiliates and subsidiaries;
  • Vendors who provide services on our behalf;
  • Online advertising services and advertising networks; and
  • Data brokers.
  1. Sale of Personal Information

We may sell certain categories of your personal information to our enterprise customers in connection with our products and services. You have the right to opt-out of this disclosure of your information.

During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information to the following categories of third parties:

Category of Personal Information

Category of Third Party

Identifiers

·       Our Enterprise Customers

·       Online advertising services and advertising networks

Protected Classifications

·       Our Enterprise Customers

·       Online advertising services and advertising networks

Geolocation data

·       Our Enterprise Customers

·       Online advertising services and advertising networks

Employment Information

·       Our Enterprise Customers

·       Online advertising services and advertising networks

Inferences

·       Our Enterprise Customers

·       Online advertising services and advertising networks

We do not have actual knowledge that we sell personal information of minors under 16 years of age.

  1. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below.

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Category of Third Party

Identifiers

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

·       Data analytics providers

·       Internet service providers

·       Operating systems and platforms

Additional Data Subject to Cal. Civ. Code § 1798.80 Law

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Protected Classifications

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Commercial Information

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Online Activity

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

·       Data analytics providers

·       Internet service providers

Geolocation data

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Sensory Information

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Employment Information

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

Inferences

·       Our affiliates and subsidiaries

·       Vendors who provide services on our behalf

·       Online advertising services and advertising networks

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with government entities, such as in response to requests from law enforcement authorities.

  1. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

  • Access:You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
  • Deletion:You have the right to request that we delete certain personal information we have collected from you.
  • Opt-Out of Sale:You have the right to opt-out of the sale of your personal information.

How to Submit a Request. To submit an access or deletion request to support@carizmaguide.com

To opt-out of the sale of your personal information email us at support@carizmaguide.com

You must provide us with your device identifier, which we will use to fulfill your opt-out request. If you do not know your device identifier, below are instructions on how to locate it. We will not use the information you provide as part of your request for any purpose other than to fulfill your opt-out request.

  • If you use an iOS operating system, a third-party application is required to locate your Apple IDFA. Please note that we do not control such third-party tools and are not responsible for their content, their privacy policies, or their use of your personal information.
  • If you use an Android operating system, open the Google Settings app on your Android device and select “Ads.” Your Advertising Identifier should be listed at the bottom of the screen.

To submit a request as an authorized agent on behalf of a consumer, please send us a notarized power of attorney and/or other legal documentation. Requests from agents that do not submit sufficient proof that they have been authorized by you to act on your behalf will be denied. For questions or concerns about our privacy policies and practices, please contact us as described in the “Contact Us” section of our Enterprise Services Privacy Policy.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we are unable to fulfill your access or deletion requests at this time because there is no reasonable method by which we can verify your identity to the level of certainty required by California law. The reason for this is that Foursquare historically has not linked IP addresses, device identifiers or other information collected through automated means to named actual persons unless the individual uses the Consumer Services.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Privacy Rights Reporting

 

Requests Received (Global)

Requests Completed in Whole or In Part (Global)

Average Days to Respond (Global)

Requests for Deletion

0

0

0

Requests for Access

0

0

0

Requests to Opt-Out

0

0

0

 

  1. More Information for Consumers From the EEA, UK and Switzerland

Where GDPR applies to the processing of your Personal Data, we rely on several legal bases. These include:

  • When the processing is necessary to perform our contract with you, such as our Terms of Service. This may include providing you with our Consumer Services or tailoring the Consumer Services to your preferences;
  • When the processing is necessary for our legitimate business interests (or those of our Enterprise Customers), including but not limited to, improving the Consumer Services or providing our Products;
  • When you have given us your consent, including as described in this Privacy Policy. You may withdraw your consent to processing at any time using the settings on your device or in your account;
  • When we have a legal obligation to do so, as described in this Privacy Policy.

Your Rights

Subject to applicable law, you may have a number of rights regarding the processing of your Personal Data, including:

  • the right to request access to, or copies of, your personal data that we process or control, together with information regarding the nature, processing and disclosure of that personal data;
  • the right to request rectification of any inaccuracies in your Personal Data that we process or control;
  • the right to request:
    • deletion of your personal data that we process or control; or
    • restriction of processing of your personal data that we process or control;
  • the right to object, to the processing of your personal data by us or on our behalf;
  • the right to have your personal data that we process or control transferred to another data controller, to the extent applicable;
  • the right to withdraw where we process your personal data on the basis of your consent, and
  • the right to file a complaint with a Data Protection Authority regarding the processing of your personal data by us or on our behalf.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your personal data, please use the contact details provided in the Contact Us section.

These rights may be limited in certain circumstances, for example if fulfilling your request would (i) reveal personal data about another person, (ii) infringe the rights of a third party (including our rights), (iii) cause us to delete information that we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.

Transfers of Data to the United States

Carizma may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we protect that information as described in this Privacy Policy. We transfer the Personal Data we collect about you to the U.S. in order to perform our contract with you or to take steps requested by you in order to enter into a contract. For example, we may transfer your Personal Data to the U.S. for the purposes of creating your account or providing our Services. We also may transfer your Personal Data to the U.S. where you have provided us with your explicit consent. Where we rely on your explicit consent, we will inform you of the purposes for which we require your Personal Data, as well as other supplementary information, at the point at which we obtain your Personal Data. Where you have provided your explicit consent, you have the right to withdraw the consent at any time by contacting us as indicated in the “Contact Us” section below.

Who is Responsible for Your Data?

Carizma is a data controller for all data collected under this Consumer Services Privacy Policy.

  1. Changes to this Privacy Policy?

Carizma may amend this Consumer Services Privacy Policy from time to time. We encourage you to regularly check this page to review any changes we might make in accordance with this Consumer Services Privacy Policy. We will indicate at the top of the Privacy Policy when it was most recently updated. If we make material changes in the way we use your data, we will notify you by posting an announcement on our Sites or Apps, or by sending you an email (if we have your email).

  1. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to our Data Protection Officer: support@Carizma.com. We will make every effort to resolve your concerns.

 

When we begin work in the EU, we will appoint Verasafe as Carizma’s representative in the (a) European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union and (b) United Kingdom for data protection matters pursuant to Article 27 of the United Kingdom General Data Protection Regulation. Verasafe can be contacted, in addition to Carizma, for matters related to the processing of your personal data only. 

If you are in the European Union and would like to make such an inquiry, please contact VeraSafe:

  • online: https://www.verasafe.com/privacy-services/contact-article-27-representative/; or
  • by mail: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland

If you are in the United Kingdom and would like to make an inquiry, please contact Verasafe:

  • online: https://verasafe.com/public-resources/contact-data-protection-representative;
  • tel: +44 (20) 4532 2003;
  • by mail: VeraSafe United Kingdom Ltd. 37 Albert Embankment London SE1 7TL United Kingdom