Privacy Policy

Last modified: July 17, 2019

TH2connect, LLC d/b/a the Togo Group (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This privacy policy explains how we collect, process, use, store and disclose your personal data, as well as your rights associated with that data.

Please also use the Glossary at the end of the document to understand the meaning of some of the terms used.

Who we are
1. The Togo Group of companies strive to improve the RV experience through innovative products, services, and technologies, including mobile applications, trip planning and booking, remote monitoring, theft tracking, and peer-to-peer RV and campsite rental services. We respect your privacy, and we believe you should be informed about what personal information we may collect when you interact with us.
2. This Privacy Policy (“Policy”) applies to personal information collected by the Togo Group Companies unless an exception applies (see below). This Policy tells you about what information we may collect and how we may process, share, and use it. Please read it carefully.
3. Note: when we reference the “Togo Group Companies”, we mean Togo Group and its wholly-owned subsidiaries and divisions (including Roadtrippers, LLC, Mighway, Togo RV Tech, LLC, CamperMate, GeoZone and Cosmos). When we reference “Togo Group”, “we”, “our”, or “us”, we are referring to the specific Togo Group company, division, or Service which is collecting and/or processing your information.
4. When we reference our “Service” or “Services”, we mean technologies, capabilities, features, applications, websites, vehicle integrations, our social media pages which reference this Policy, and other products and services and communication channels we may provide (including mobile applications, trip planning, remote monitoring, theft tracking, peer-to-peer RV and campsite rental services).
5. This Policy does not apply to:
  1. any Service that has a separate privacy policy which does not incorporate this Policy; or
  2. third party cookies, and/or third-party products or services (including websites, platforms features, app stores, and applications), all of which are governed by their own respective privacy policies (even if our Services contain them, use them, or link to them). We are not responsible for third party privacy practices.
6. Note: You have a choice as to whether you want to share personal information with us. If you choose not to provide us with certain information, we may not be able to offer you certain Services, you may not be able to access certain features of the Services, or the Services may not function properly or at all.

The data we collect about you

This policy applies to information we collect
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
1. Identity Data includes first name, last name, username or similar identifier, title, date of birth, age, gender, driver license and passport details.
2. Contact Data includes address, telephone numbers and email address.
3. Financial Data includes payment card details.
4. Transaction Data includes details of your previous bookings with us, payments to and from you and other details of Services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
6. Location Data includes global position system vehicle tracking and diagnostics (telematics) and other location information obtained from smartphones, tablets, sat-navs or other devices that monitor your current and previous geographic locations.
7. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
8. Usage Data includes information about how you use our Services.
9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
10. Vehicle-sourced Data includes information collected by data systems within a vehicle about its condition and performance (including mileage, fuel and other operational data) and your operation of the vehicle, including your speed, time, fuel consumption and distances travelled.
We also collect, use and share Aggregated Data such as statistical or demographic data, which may be derived from your personal data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Services. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat that combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Sensitive Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offense, although we may be required to briefly hold and pass on any driving infringements that you incur while renting our vehicles or vehicles rented in connection with our Services.
Children under the Age 13: We do not knowingly collect personal information from children under 13 years of age. No one under age 13 may provide any information to or on our Services. If you are under 13, do not use or provide any information through our Services or their respective features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.
Consent to Policy; Refusal to provide your personal data: Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this privacy policy. You do not have to provide your personal data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you (for example, to provide you with a rental vehicle). That may mean we have to cancel a Service you have with us. We will notify you at the time if that is the case.

How we collect your personal data

We use different methods to collect personal data from and about you including through:
1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites and mobile applications and other Services, on third-party websites, applications, or services, or in paper form or by corresponding with us by post, phone, email or otherwise. That includes personal data you provide when you:
  1. make an inquiry or booking with us or otherwise apply for any of our Services
  2. purchase a Service from us
  3. create an account on our Services
  4. subscribe to our Services or publications
  5. request marketing to be sent to you
  6. enter a competition, promotion or survey in connection with our Services (including on third party social media platforms)
  7. give us feedback
  8. enter our premises on which security cameras are operating
  9. speak to us on the telephone
2. Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns, including:
  1. Details of your usage of our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use in connection with the Services.
  2. Information about your device and internet connection, including your IP address, operating system, and browser type.

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We may combine Technical Data (some of which will be anonymous) with other personal data we have collected from you in order to understand and measure your online experiences and determine what products, promotions and services are likely to be of most interest to you.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on your device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website or other Services.
Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third parties or publicly available sources. We may receive personal data about you from various third parties including our business partners and certain public and technical sources:

Technical Data from analytics providers such as Google and advertising networks such as Facebook and Identity, Location and Vehicle Sourced Data when using our vehicles or vehicles rented in connection with our Services.
Identity and Contact Data from data brokers or aggregators such as Facebook, from third party business partners, and from publicly availably sources such as phone directories, membership lists, professional and trade associations, government, bankruptcy or court registry searches and electoral registers.
Identity, Contact and Profile Data from our business partners that use our application(s) to market Togo Group Services.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on our websites and other Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Unsolicited personal data.

If we receive personal data that we have taken no active steps to collect (such as a job application sent to us by an individual on their own initiative, rather than in response to an advertisement), then we may keep that personal data if it is reasonably necessary for one or more of our functions or activities. We will destroy it or ensure it is de-identified, provided it is lawful and reasonable to do so.

How and why we use your personal data

We will only use your personal data when the law allows us to and typically only in the circumstances and for the purposes set out in the table below. Please see the Glossary for an explanation of the expressions used in the table.

Purpose/Activity

Type of data

Lawful basis for processing

New customers: To provide, administer, protect, and enhance our Services, to enhance user experiences, and to develop new Services

(a) Identity

(b) Contact

Performance of a contract with you

Provide services: To provide our Services to you, including:

register your account(s) and purchased subscriptions and Services, and to provide customer support (including assisting you with your account and solving other problems you may experience)
respond to your inquiries, to help you solve problems you may be experiencing, provide support regarding your account and our Services, to otherwise communicate with you managing our vehicles or vehicles rented in connection with our Services

(a) Identity

(b) Contact

(d) Financial

(e) Transaction

(f) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

Relationship management:

To manage our relationship including:

inform you about changes or enhancements to our Services and changes to our Services, terms of use, and policies
asking you to leave a review or take a survey
keeping you up to date with our latest news

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Improve Services:

To constantly improve our Services, tailor them to your needs, develop new Service ideas and inform you of any changes to our Services
To conduct and facilitate market research (including surveys, data analytics, market research, financial analysis, and customer segmentation)
To engage in ad retargeting and evaluation of the effectiveness of marketing efforts (including through participating in ad networks)

(a) Identity

(b) Contact

(d) Marketing and Communications

a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep developing and improving our Services in line with customer expectations)

Promotions/ Advertisements:

to communicate about, promote, and administer our Services, events, programs, and promotions (including sending marketing communications, promotional materials, notices, alerts, newsletters and conducting sweepstakes and contests)

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business)

Technical maintenance:

To administer and protect our business, content, websites and mobile apps including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring for unauthorized use
To maintain and promote the safety and security of our Services, our IT network, and our employees

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Transaction

(g) Location

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)

(b) Necessary to comply with a legal obligation

Data analytics:

To perform data analysis to:

improve and personalize your experience on our platforms
improve our Services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(d) Profile

(e) Marketing and Communications

Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Promote our Services:

To provide you with information and ads about third party offers, merchants, attractions, locations, and Services which may be nearby or which otherwise may be of interest to you
To conduct marketing and sales activities (including lead generation, pursuit of marketing prospects, market research, managing and evaluating the effectiveness of advertising and marketing efforts, and managing our brands)

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Location

(g) Marketing and Communications

Necessary for our legitimate interests (to develop our Services and grow our business)

Safety and security:

To verify your identity and to protect against unauthorized transactions, fraud, and other unlawful activity, claims and other liabilities, and to manage risk exposure and quality
To track vehicle location and provide real-time safety alerts to customers (such as low bridge warnings), notifications of access to unauthorized territories, information about points of tourism interest, to contact you about security, safety and/or operational issues we have identified from the data collected, and to understand and manage the performance, location and security of our vehicle fleet and to assist with the management of accident claims involving our vehicles or vehicles rented in connection with our Services

(a) Identity

(b) Contact

(d) Location

(e) Vehicle-sourced data

(f) Usage

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Other:

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); to conduct investigations; to comply with and enforce applicable legal obligations, relevant industry standards, other contractual obligations, and our terms, policies and procedures
To fulfill any other purpose for which you provide it or for which you give consent.

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

Marketing

We aim to provide you with choices about how your personal data is used for marketing and advertising purposes.

You will only receive marketing communications from us if you have opted in or consented to receiving those communications. We may use your personal data collected in those circumstances to contact you and keep you up to date with the latest news, events, special offers and promotions of our brands, including by email, text messages or post.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form). For more information, see Choices About How We Use and Disclose Your Information.

You can update your subscription preferences or unsubscribe from marketing communications at any time by following the update preferences or unsubscribe instructions provided in each such communication, or alternatively by contacting us by clicking here.

We may display advertising for you to see on third party websites, including social media sites such as Facebook. We do this by matching information about your activity on Togo Group websites with information collected on third party sites. That may involve using your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by clicking here.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we share your personal data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may have to share your personal data with the following parties for the purposes set out in the table in paragraph 4 above or for other purposes directly related to the purpose for which the information was collected.

Togo Group Companies: We may share personal information with the Togo Group Companies when consistent with the purposes set forth in this Policy. Other companies in the Togo Group group acting as joint controllers or processors and who are based in Australia, New Zealand, the & United States and provide IT, storage and system administration services and undertake leadership reporting. These third-party service providers are contractually bound to keep personal information confidential, to maintain adequate safeguards, and use it only for the purposes for which we disclose it to them or to comply with legal requirements.
Service providers: We may also share personal information with affiliates, contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, providing the following services:
1. Payment processing
2. Data processing
3. Order fulfillment
4. Customer Support
5. IT and system administration
6. Marketing, market research and communication
7. Printing and distribution of marketing materials
8. Mailing, freight and courier
9. Price comparison websites
10. Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, consultants, insurers and recruiters
Other third parties:
1. regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances and/or where disclosure is required by law
2. A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of any Togo Group’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information we hold is among the assets transferred
3. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice
4. other entities in the same or similar industries to us, for reasons of public safety
5. where the law requires or authorizes us to do so
6. To fulfill the purpose for which you provide it
7. other third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce or apply our Terms of Use and other agreements.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Togo Group Companies, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Choices about How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to privacy@togogroup.io.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own Services or third parties’ products or services, you can opt out by sending us an email stating your request to privacy@togogroup.io. If we have sent you a promotional email, you may opt out by clicking the relevant unsubscribe link in the email or by sending us a return email asking to be omitted from future email distributions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to privacy@togogroup.io.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

International transfers

For the most part, your personal data is collected, stored and processed outside the European Economic Area (EEA).
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we have entered into EU-approved standard contractual clauses with the recipient to give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they demonstrate an adequate level of data protection in compliance with applicable law.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Your rights
Depending on your jurisdiction, you may have the following rights in relation to your personal data.

Access: you can request access to a copy of the personal data we hold about you and to check that we are lawfully processing it.
Correction: you can request that any incomplete or inaccurate data we hold about you is corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure: you can ask us to delete or remove your personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing: where we are relying on a legitimate interest (or those of a third party) and you believe our processing of your personal data impacts your fundamental rights and freedoms, you may object to such processing for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
Restrict processing: you can ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Data portability: you can request that your personal data is transferred to you or a third party. We will provide you or a third party you have chosen with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent: you may withdraw your consent to our processing of your personal data. If you do so, we may not be able to provide certain products or services to you. We will advise you if that is the case when you withdraw your consent.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@th2.com or write us at: Togo Group, Attn: Privacy, 601 E. Beardsley Ave., Elkhart, IN 46514.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer (see section 12 below).

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If we choose to deny your request, we will inform you of the decision and your right to complain to the supervisory authority within the one month deadline.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure that personal data is not disclosed to any person who has no right to receive it.

Time limit to respond: We respond to all legitimate requests without undue delay and at the latest within one month. Occasionally, if your request is particularly complex or you have made a number of requests, we may need to extend this by up to a period of two months, in which case we will notify you and keep you updated.

Security of your personal data
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures provided in connection with any of our Services.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Contact Details

EU Supervisory Authorities: If you are an EU data subject and feel that your personal data has been processed in a way that does not comply with the GDPR, you may lodge a complaint with the relevant supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.

Data Protection Officer: We have appointed a data protection officer (DPO) who is responsible for overseeing privacy issues for the Togo Group Companies. If you have any questions or complaints about this Policy, including any requests to exercise your rights in relation to your personal data, please contact the DPO using the details set out below.
Name: Mark Taylor
Email address: privacy@togogroup.io
Postal Address: Private Bag 92133, Auckland, New Zealand 1142
EU Representative: We have appointed an EU Representative whose tasks are to serve as a contact person for supervisory authorities and data subjects and can be contacted as follows:
Email address: privacy@togogroup.io

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 13 September 2018. We reserve the right to update and change this Privacy Policy at any time by posting changes on this webpage, applicable mobile apps or via other channels that we think are suitable. It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the www.togogroup.io home page. The date the privacy policy was last revised is identified at the top of the page.

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting www.togogroup.io and this privacy policy to check for any changes. Please keep us informed if your personal data changes during your relationship with us.
Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

GLOSSARY

Comply with a legal or regulatory obligation means processing your personal data where that is necessary for compliance with one of more of our legal or regulatory obligations.

Data controller means whomever determines the purposes and means of processing personal data.

Legitimate Interest means our interests in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where that is necessary under a contract with you or to take steps at your request before entering into such a contract.

Personal data means any information about an individual that can be used to identify that person directly or indirectly by reference to a range of identifiers. It does not include anonymous data where the identity of the individual has been removed.

Processing means any operation or set of operations performed on personal data.

Processor means the entity that processes personal data on behalf of the controller.

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