Effective on June 18, 2013
Information Provided Directly by You
When you request information on the Cumswappingtwinks website about the AR VOD Service or sign up for a free trial AR account, we may ask you to provide us certain Personally Identifiable Information (hereafter "PII") about yourself, such as your name, age and email address. You will always know when the AR Web Site collects these types of PII because you will have to supply that information to us or give your permission for us to collect that information.
When you establish a paid account for the AR VOD Service we may request from you your name, age and email address, as well as additional PII such as credit card information or checking account details (including the associated billing address). Again, you will know when we collect these types of additional information from you because you will have to provide it to us.
Information We Collect by Automated Processes
The AR Web Site uses information collected through technology to make our site and Service more interesting and useful to you, as well as to supplement our security and anti-fraud measures. These automated collection processes include active and passive logging by our web servers, and in some circumstances it may not be immediately apparent to you that such information is being collected. The information collected through technology is limited to that which your access point is configured to provide, and is the same data that is available and collected by standard passive logging techniques used by most public web sites. This information may include IP Address, Browser type, time/date-stamp, referring URL and the visited page. Your IP address is associated with the means by which you access the Internet and may be generic to your ISP (Internet service provider), your company, or your university. On its own your IP address is not personally identifiable. Such information will not be associated with your PII except indirectly for automatic fraud protection and other security procedures.
At times we also collect information regarding frequency and patterns of navigation of visitors to the AR Web Site for the purpose of improving the individual user experience, as well as for generalized extrapolated data pertaining to popularity and usability of the Service. We may combine this information with PII to identify a visitor in order to provide improve and enhance navigational aspects of The Service, provide relevant content and ads to that visitor, as well as to ensure compliance with our Terms of Service and as part of our anti-fraud measures.
Such automatically collected data will not be shared with any third parties, except in the case of providing generalized aggregate data to our affiliates, in which case there will be no means of extracting any PII from that data. Unaggregated data will only be shared in order to ensure compliance with a legal subpoena where utilized under applicable local laws as described below.
Cookies and Web Beacons, and How the AR Web Site Uses Them
Cookies are a standard Internet technology that allow a web browser to store relevant information about a given web site. Cookies may be used by the AR Web Site to store login and navigation information to improve your user experience, providing such functionality as enabling you to log in automatically to the AR Web Site when returning for a future session, or to remind you of previously used content that you may more efficiently navigate the Service. Cookies are optional for the Service and your web browsing software (such as Firefox or Internet Explorer) may be configured by you not to store such information. Consult the 'Help' information for your particular browser for further information on disabling Cookies, although this may adversely affect the usability of the Service.
We collect PII for several purposes. Name, credit card/banking details and date of birth are collected both for billing and age-verification purposes. We collect name and email addresses for administrative contact purposes pertaining to account details and user billing, to keep our users updated on new features and updates to the Service, as well as the sending by us of occasional promotional and marketing details for other services offered by Prolast and select third parties. All non-operational mails are completely optional on an opt-out basis.
The collected non-personal information, such as automatically collected navigation and traffic details, are used to improve the Service, enhance navigation and may be supplied in generalized aggregate format to our affiliates as part of a statistical analysis of traffic trends. Additionally such information is used in conjunction with PII as part of our anti-fraud and security measures to ensure the integrity of the AR VOD Service, to enforce and protect the Terms of Service and to personalize or customize select marketing or promotional communications.
Information gathered via direct email communication with users will be used for relevant internal purposes, such as improving response time for similar support requests, service enhancement and staff training, in addition to the other uses outlined in this document.
Except in the specific cases outlined below, Prolast will not share your PII with third parties under any circumstances.
Credit card and billing processors
When you subscribe to the AR VOD Service we collect certain PII from you, including name, email address and credit details. If the account is not directly processed through Prolast's merchant billing service then credit details may be shared as necessary with third party credit processors who will use it solely for the billing procedures authorized by the user. In such cases, the PII will be transferred across an encrypted Internet connection subject to stringent security checks, and stored by the Processors solely for their own legally defined audit procedures. Any external credit processors used by Prolast are subject to rigorous standards checks to ensure their data integrity meets the required standard, and all data provided to them is protected and governed by strict non-disclosure agreements.
Sale of Business
Disclosures Required By Law
We may disclose personally identifiable information concerning you to a law enforcement agency pursuant to a warrant issued under applicable criminal codes, an equivalent Provincial warrant, a grand jury subpoena, and certain court orders. To the extent permitted by law, we may also disclose personally identifiable information concerning you in order to enforce our Terms of Service, our web site rules, and to protect the safety and security of our web site, ourselves and others.
Non-Personally Identifiable Information
We may share aggregated or anonymized information in other ways, but in these cases any personal details or means of identification will be stripped from the data. Such uses may include, but are not limited to, statistical data provided to affiliates, traffic data provided to potential affiliates to promote the service and usage data provided to third parties such as content providers or potential advertisers.
When you register for the AR VOD Service you agree to our Terms and Conditions which include all usages of data outlined above. With the exception of the 'Welcome' or 'Confirmation' emails necessary to confirm your signup to the Service, you have full opt-out control over the usage of your personal data for such purposes that are not strictly necessary for the operation of the Service. Upon signup you will have the opportunity to choose to receive or not to receive promotional materials from Prolast. You also may modify your choice regarding receiving promotional materials by contacting AR customer care using the details supplied below, by clicking on unsubscribe links in relevant emails, or by using any of the contact methods outlined below. Unsubscribe links in emails are fully functional for at least 30 days from the date of mailing, and modification requests will be followed within 10 days from our receipt of such a request. Such requests will be enabled through the use of an active suppression list, but it should be noted that subsequent uses of the same details for services provided by Prolast will be considered to supersede the previous request.
We protect the integrity and security of your data through our strict technical and administrative procedures. These include but are not limited to firewalls, encryption methods such as HTTPS and SSL, frequent security audits, active and passive scanning and attack simulation, password protection, physical protection of servers, employee privilege levels, staff meetings and briefings and internal disciplinary procedures for potential breaches.
Cumswappingtwinks Privacy Czar 171 East Liberty Street Unit 220, Toronto, ON M6K3P6