Effective Date: March 1, 2021
Remember that your use of The Intercooler’s Services is at all times subject to the Terms and Conditions. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.
We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalise, provide, and improve our Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfil your requests for certain products and services, and to analyse how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.
We do not knowingly collect or solicit Personal Data from anyone under the age of 13 (or under the age of 16 in the European Union). If you are under 13 (or 16 where applicable), please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13 (or 16 where applicable), we will delete that information as quickly as possible. If you believe that a child under 13 (or 16 where applicable) may have provided us Personal Data, please contact us at email@example.com.
What information does The Intercooler collect?
Information You Provide to Us
We receive and store any information you knowingly provide to us. For example, through the registration process and/or through your account settings, we may collect Personal Data, including without limitation, the following:
- First and last name
- Email address
- Mailing Address
- User content and other information you directly upload to the Services i.e. in comments sections, which can include Personal Data if you include Personal Data in such content
Certain information is required to register with us, subscribe to our Services, or to take advantage of our features. We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services. If you do not want to receive communications from us, please indicate your preference by updating your account settings or clicking ‘unsubscribe’ in our emails.
Information Collected Automatically
Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which include the following:
- IP address
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
- Device identifiers
- Web browser information
- Page view statistics
- Usage information
- Location information
“Cookies” are identifiers we transfer to your browser or device that allow us to recognise your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.
We use third party analytics services in order to better understand user engagement with the Website. When a user browses or uses the Website, these third party analytics services may collect the user’s IP address, browser type, and approximate location (based on the IP address). They may also use web logs or web beacons and may set and access cookies on your computer or other device.
We may use this data to customise content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Do Not Track Policy
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity while you are using the Services.
Information Collected from Third Parties
We collect Personal Data about you when third parties, such as our business partners or service providers, provide us with Personal Data about you. Such third parties provide us with Personal Data about you, such as the following:
- Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect or Twitter OAuth), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity,” meaning that we need to process the data to perform under our Terms of Service, as well as any other agreements with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
- Your full name
- Your user name
- Your email address
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- Your mailing address
- Your IP address
- Your user content
- Your usage information
- Examples of these legitimate interests include:
- Operation and improvement of our business, products, Services, and Content
- Marketing our products and Services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with our legal obligations outside of the EEA
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with an EEA legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Will The Intercooler share any of the personal data it receives?
We do not rent or sell your Personal Data to anyone at this time. We may share your Personal Data with third parties as described in this section:
Information that’s been de-identified. We may de-identify your Personal Data so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.
Affiliated Businesses: In certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognise when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies.
- Payment processors (e.g. to receive and process your credit card transactions for us)
- Fraud prevention service providers
- Analytics service providers
- Staff augmentation and contract personnel
- Hosting service providers
- Co-location service providers
- Telecommunications service providers
Unless we tell you differently, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.
User Profiles and Submissions: Certain user profile information, including your name, location, and any content that you have uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.
Business Transfers: We may choose to buy or sell assets, and may share and/or transfer user information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Data could be one of the assets transferred to or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
Protection of The Intercooler and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to:
- comply with applicable law, court order, or respond to valid legal process, including from law enforcement or other government agencies;
- prevent spam or other unwanted communications and investigate or protect against fraud;
- maintain the security of our products and Services;
- protect the rights, property, or safety of The Intercooler, our employees, our users, or others.
Consent: We also share information with third parties when you give us consent to do so.
Affiliates: we share Personal Data with our affiliates or other members of our corporate family.
Is Personal Data about me secure?
Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorised access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We seek to protect Personal Data using appropriate technical and organisational measures based on the type of Personal Data and applicable processing activity. Our information is stored on secure servers. Our security measures vary based on the sensitivity of the Personal Data we collect, process and store and the current state of technology. We also take measures to ensure subprocessors that process Personal Data on our behalf also have appropriate security controls in place.
We endeavour to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We take various steps to protect your information, including, but not limited to, the following:
- We implement technical measures to prevent unauthorised access, and keep security patches and software up-to-date
- We restrict employee access to your information on a need-to-know basis
- We store sensitive Personal Data in encrypted form
- We encrypt all Personal Data during transfer
What rights do you have regarding your Personal Data?
If you are a resident of the EEA, you have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is extremely impractical, if it jeopardises the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Opt not to Disclose: You can always opt not to disclose information to us by emailing us at email@example.com; however keep in mind some information is required to register with us and to maintain an account.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. When you update information, however, we may maintain a copy of the unrevised information in our records.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about The Intercooler’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
How long do we retain your Personal Data?
We retain Personal Data about you for as long as you have an open account with us and for six (6) years after you terminate your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
Afterwards, we retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
Do we transfer EU users’ Personal Data outside the EU?
At The Intercooler
By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to The Intercooler in the UK and will be hosted on UK servers, and you authorise The Intercooler to transfer, store and process your information to and in the UK, and possibly other countries. You hereby consent to the transfer of your data to the UK as set forth herein.
What if I have questions about this policy?