Privacy Policy





Overview

Stripe Media Inc. (the parent company of the site you are on) has always taken a light touch to the collection, use and storage of the information or data we collect from our free and paid users. Our philosophy has been to collect, use and keep only the data necessary to provide the services expected by you at our site and what is necessary to remain in touch with our past customers and clients via occasional marketing emails containing offers from us and our hand selected partners. As of May 24th Stripe Media has fully adopted, implemented and become compliant with the EU General Data Protection Regulation (GDPR), the details of which can be found here GDPR https://ec.europa.eu/info/law/law-topic/data-protection_en. The compliance with this set of protections ensures our customers and partners that they can feel safe in regards to how we treat and use their personal data.

This document has been created to explain how we collect, use, share and store the data we have obtained through your use of our network of sites and online services. This privacy policy covers information collected from our network and via direct communications between you and us here at Stripe Media. By using this service you are consenting to this collection, use, sharing and storage of your information and personal data. By using this service you are agreeing to the terms of this policy. We will only process your data in accordance to current data protection and privacy laws. For the purpose of the UK and EU data regulations our data controller is Stripe Media, Inc. C/Guillem de Castro 105, 5, 9 Valencia, Spain 46008.

The Data we collect automatically

Stripe Media and its third party service providers (this includes content, advertising and analytic services) automatically collect data from the device you are using when you interact with our sites. This may include your IP address, details about your mobile device, browser or computer, where you came from and how you interact with our site. The data we collect is solely used to enhance your experience with our site and is not used to target ads or additional services to you. We collect a minimal amount of data to provide you the site access you expect.

The Cookies/Tracking Technologies We Use

Stripe Media uses tracking technologies, such as cookies, local storage, and pixel tags.

Local Storage and Cookies

Cookies and local storage are set on your computer. When you first visit our site, a cookie or local storage will be sent to your computer that uniquely identifies your browser. "Cookies" and local storage are small files that are sent to your computer's browser and stored on your device when you visit a website. All the popular browsers are initially set up to allow the addition of tracking cookies. You can modify your browser to customize your cookie settings. Lastly you clear all cookies on your browser whenever you want by setting your browser to refuse all cookies or indicate when a cookie is being added to your browser. This can be done at any time.

Our sites use the following cookies and use them for the purposes below:

Pixel Tags

We occasionally use "pixel tags," which are small graphic files that allow us and third parties to monitor the use of the Services and collect Usage Data. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time (and length of time) the page containing the pixel tag was viewed; the type of browser that retrieved the pixel tag; and the identification number of any cookie previously placed by that server on your computer.

We use pixel tags, either provided by us or by our third-party service providers and ad networks, to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and Services and use them in combination with our cookies to provide offers and information of interest to you. Pixel tags also enable ad networks to serve targeted advertisements to you when you visit the Services or other websites.

In addition, we use a variety of other technologies that collect similar information for security and fraud detection purposes.

For more information about the use of cookies and similar technology on our Site, please review our cookie policy.

The Information you submit

You can visit our sites without revealing any personal data. However, if you wish to register to become a member of the sites as either a free or paid member you will be required to provide several pieces of Personal Data (for example, your name and e-mail address), and you must also provide a user name and password. We use your Personal Data to fulfill your requests for products and services, to improve our site, to contact you from time to time, with your consent, about us and our products and services, and as otherwise described in this Privacy Policy. Failure to provide any required Personal Data will prevent us from being able to provide the Services you request (e.g., member registration or site membership) or otherwise inhibit our ability to provide you with access to our sites and services.

How We Use Your Information

We use the information we collect, including Personal Data and Usage Data:

- to enable you to use our sites, to create an account or profile, to process information you provide via our Services (including verifying that your email address is active and valid) and to process your transactions;
- to provide related customer service and care, including responding to your questions, complaints, or comments and sending surveys (with your consent) and processing survey responses;
- to provide you with information, products, or services that you have requested;
- with your consent, to provide you with information, products, or services that we otherwise believe will interest you, including special opportunities from us and our third-party partners;
- to tailor content, recommendations, and advertisements we and third parties display to you, both on the Services and elsewhere online;
- for internal business purposes, such as to improve our Services;
- to contact you with administrative communications and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of our other policies;
- to comply with regulatory and legal obligations; and
- for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Our Practice for Sharing Information

1. Generally, we share Non-Personal Data, including Usage Data, de-identified Personal Data and aggregated user statistics, with third parties in our discretion. We share User Information, including Personal Data, as otherwise described in this Policy, and under the following circumstances:
2. Service Providers. From time to time, we enter into relationships with third parties who provide services to us (for example, analytics companies, advertisers and ad agencies, data management and storage services or credit card processing services). In those circumstances, we disclose User Information so that such service providers perform those services. These service providers are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your Personal Data. In particular, our sites use certain Google analytics and other services, and certain pages use the Google AMP Client ID API, each of which enable collection and sharing of your information (including Personal Data) with Google for further use. For specific information on Google usage and how to control it, please see How Google uses data when you use our partners' sites or apps and Google?s Privacy Policy.
3. Third-Party Marketing. You will have a choice (opt-in or opt-out) before we share your information with third parties for marketing purposes. Provided that you have chosen to receive marketing messages from third parties, we share your information (including Personal Data) with third parties for those third parties' own direct marketing purposes. Please note, messages delivered from a third-party will subject you to the third-party's privacy policy. We also match your email address with third parties with whom you have also consented to share your email address and use such match to deliver custom offers or emails to you on the Services and off the Services provided you have consented to receiving such offers or emails.
4. Change of Control. In the event we go through a business transition (such as a merger, acquisition by another company, bankruptcy, or sale of all or a portion of our assets, including, without limitation, during the course of any due diligence process), your Personal Data will likely be among the assets transferred. By providing your Personal Data, you agree that we can transfer such information in those circumstances without your further consent. Should such a business transition occur, we will make reasonable efforts to request that the new owner or combined entity (as applicable) follow this Privacy Policy with respect to your Personal Data. If your Personal Data would be used contrary to this Privacy Policy, we will request that you receive prior notice.
5. Other Disclosure Scenarios. We reserve the right, and you hereby expressly authorize us, to share User Information: (i) in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims; (ii) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (iii) if we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of information); (iv) to protect and defend our legal rights or property, our services or their users, or any other party, and to protect the health and safety of our users or the general public; and (v) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy).

Data that is Anonymous

When we use the term "anonymous data," we are referring to data and information that does not permit you to be identified or identifiable. We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data will include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

Your Public Information

If you identify any User Information as public, you are authorizing us to share such information publicly. For example, you can elect to make certain of your User Submissions (such as your alias, bio, email or avatar photos) publicly available. Also, there are areas of the Services (for example, message boards, discussion rooms, other online forums and chats) in which you are able to post information that automatically will be available to all other users of the Services. By choosing to use these areas, you understand and agree that anyone can access, use, and disclose any information that you post to those areas.

Financial Information

All financial data will only be shared with the site's third party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors. Said processors only use your information for that purpose. All financial data and information shall be considered private information and will not be shared by the site with third parties except with your authorization or when necessary to carry out all and any transactions requested by the user with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party and all transactions are not governed by this Privacy Policy. All such information provided to a third party is subject to their terms and conditions.

Consent to Transfer as it Pertains to Users Outside of the U.S.

Our sites and services are operated in the United States. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to, stored and processed in the United States. By using the Services or providing us with any information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws are not as comprehensive as those in the country where you reside or are a citizen such as the European Union. You understand that the U.S. government can obtain access to the Personal Data you submit if necessary for investigative purposes (e.g., terrorism investigation). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We use appropriate and suitable safeguards for transferring your Personal Data to the U.S. (e.g., standard contractual clauses issued by the European Commission, which can be accessed here).

Information for California Residents-The Californian Privacy Rights

As stated elsewhere in this Privacy Policy, Stripe Media does not share Personal Data with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us at support@solotouch.com. You must put the statement "Your California Privacy Rights" in the subject of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you.

Advertising

1. Generally, we use other companies under agreements with us to serve third-party advertisements when you visit and use our sites. These companies collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the Services and other Web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use tracking technologies to collect this information. Other companies' use of their tracking technologies is subject to their own privacy policies, not this one.
2. Targeted Advertising. In order to serve offers and advertisements that may be of interest to our users, we display targeted advertisements on the Services, or other digital properties or applications in conjunction with our content, based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Data to our advertisers when you interact with an advertisement.

Your Opt-Out Options From Our Emails

We offer you the opportunity to manage your communications from us. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us or our third-party partners. Users may elect to modify their preferences by following the "Communications Preferences" and/or "Unsubscribe" link provided in an email or communication received. You may also be able to change your preferences by updating your profile or account, depending on which of our Services you are using. Please be aware that if you wish to remove yourself from a newsletter and/or other marketing emails from third parties that you consented to through the Services, you must do so by contacting the relevant third-party. Even if you do opt-out of marketing emails, we reserve the right to send you transactional and administrative emails including those related to the Services, service announcements, notices of changes to this Privacy Policy or other Services policies, and to contact you regarding any goods or services you have ordered.

Deleting, Retaining or Modifying Your Personal Data Held By Us

You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Us section below. If you would like to update, correct, modify or delete from our database any Personal Data you previously submitted to us, please let us know by accessing and updating your profile. If you delete certain information you may not be able to order services in the future without re-submitting such information. We will comply with your request as soon as reasonably practicable. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (for example, when you enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such promotion). We will retain your Personal Data for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

EU Resident Data Rights

If you are a resident of the European Economic Area (EEA), you have the right to: (a) request access to your Personal Data and rectification of inaccurate Personal Data; (b) request erasure of your Personal Data; (c) request restrictions on the processing of your Personal Data; (d) object to processing your Personal Data; and/or (e) the right to data portability ("collectively, "Requests"). We can only process Requests from a user whose identity has been verified. To verify your identity, please provide your email address and URL at which you engaged in a relationship with ut when you make the request. For more information about how to get access to Personal Data and for exercising your rights, you can contact us at support@solotouch.com.

Our Security

We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your User Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Us section below.

Our Links Out

The Services contain links to other websites that we do not control, and the Services contain videos, advertising and other content hosted and served by third parties. We are not responsible for the privacy practices of any third-party.

Children's Privacy

This is an adult site that expressly and strictly limits its membership to adults. This site does not knowingly seek or collect any personal information or data from persons under the age of 18. All persons under the age of 18 are strictly prohibited from accessing or viewing the contents on this site without exception. If you are under the age of 18 and/or under the age of majority in the jurisdiction you reside and from which you access the website, then your account will be terminated without notice or delay.

Your Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. If you send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to our Services.

Changes and Updates

This document will be updated as necessary. Reviews to these policies are conducted annually and updated immediately as new laws and regulations come into effect by Stripe Media Inc. ownership. If the process changes it will be updated and/or amended in this document.

Get in Touch with Us

If you have questions about this or any of our other policies, please contact us by email at support@solotouch.com.




Our Internal Data Privacy Policy



Introduction

This Procedure will show how Stripe Media Inc. controls Data within the company and with other partners.

Scope

This applies to Stripe Media Inc. employees, third-parties, service providers, contractors, temporary employees, and/or other staff members at Stripe Media Inc., whether conducting activities on Stripe Media Inc. premises or off-site. This covers all systems, applications, and equipment owned or leased by Stripe Media Inc. whether located on Stripe Media Inc. premise or off-site, and all Stripe Media Inc. locations where cardholder data is present.

Review Schedule

Reviews to these policies are conducted annually and updated immediately as new laws and regulations come into effect by Stripe Media Inc. ownership. If the process changes it will be updated and/or amended in this document.

Distribution

This procedure is to be disseminated to all associates at Stripe Media Inc., to include Stripe Media Inc. employees, third-parties, service providers, contractors, temporary employees, and/or other staff members.

Data Control

The appropriate label should be used for the level of data being handled. Categories of Stripe Media Inc. information based upon intended use and expected impact if disclosed. Data classifications are defined by data owners with the exception of credit card data which is explicitly defined and protected by this Data Privacy Policy.

Stripe Media Inc. employees create records as part of the normal course of conducting the business of the company. These records document the decisions and activities of our complex educational and business enterprise. It is essential that they be created and maintained appropriately throughout their entire life cycle.

Sensitive information contained in Stripe Media Inc. records constitutes an area of critical concern because of the severe risk to the company should records be mishandled or information inappropriately accessed or disclosed. Therefore, records containing sensitive information should exist only in areas where there is a legitimate and justifiable business need.

Employees should work to identify and track all Stripe Media Inc. records through their life cycle by way of records retention schedules and as defined by state law. A priority in this effort should be the identification of sensitive information. Records and schedules will document the existence of these materials, the rationale behind keeping them, and help ensure their availability during the period in which they are vital as either, active administrative or historical records. Record retention schedules also will work to ensure the timely disposal of non-permanent, inactive records, thereby mitigating the risk of exposure of information when it no longer serves an active administrative or historical function.

Access

Sensitive information requires strict control, very limited access and disclosure, and may be subject to legal restrictions. In some cases, information is sensitive because it has been aggregated into a single document.

Only Stripe Media Inc. employees who have authorization from the data owner(s), and have a signed confidentiality agreement on file, may have access to sensitive information. Any other disclosure of sensitive information requires the written approval of the appropriate Officer of the company. Things to remember when working with sensitive data:

1. As a rule, employees are not allowed to take sensitive data home (or to make unofficial copies)
2. Where access to sensitive data has been authorized, use of such data shall be limited to the purpose required to perform Stripe Media Inc. business.
3. Users will respect the confidentiality and privacy of individuals whose records they access, observe ethical restrictions that apply to the information they access, and abide by applicable laws and policies with respect to accessing, using, or disclosing information.
4. Notification of a user?s termination or removal of authorized access to sensitive information must be conveyed immediately to the Stripe Media Inc. security group.

Use and Transmission

The following controls are required when using, transmitting or disposing of sensitive information:

- Do not discuss or display it in an environment where it may be viewed or overheard by unauthorized individuals.
- Do not leave keys or access badges for rooms or file cabinets containing such information in areas accessible to unauthorized personnel.
- When printing, photocopying or faxing it, ensure that only authorized personnel will be able to see the output.
- Store paper documents in a locked drawer and in a locked room, or in another secure location approved by the Data Owner.
- Properly identify such information as sensitive to all recipients, by labeling it "Sensitive", providing training to personnel, explicitly mentioning the classification, or similar means.

Encrypt electronic information using a generally available encryption algorithm such as that built-in to common office automation applications (such as newer versions of Word, Excel, PowerPoint, Acrobat, Zip, etc.):

- Placing it on removable media;
- Placing it on a mobile computer (e.g., laptops, iPad, smart phones); or
- Sending it via e-mail to non-Stripe Media Inc. employees.
- Do not send this information via email, instant message, chat or unsecured file transfer (such as FTP) unless it is encrypted.
- Follow an established and documented software development lifecycle when building applications that process sensitive information.

Transport

As a rule, employees are not allowed to remove sensitive data from an approved secure location without prior approval of the data owner.

If an individual employee or job responsibility requires sensitive information to be removed from Stripe Media Inc., the information (whether electronic or paper) must be protected at all times from inappropriate disclosure. Each department that has individual employees or positions requiring sensitive data to be removed from Stripe Media Inc. must have appropriate procedures in place for protecting the data while outside Stripe Media Inc. and destroying the data when it is no longer required to perform the job. The following controls are required when transporting sensitive information:

When transporting storage media containing company software or data between company locations yourself, other than your own company-issued PC/laptop, cell phone, smartphone, tablet or similar mobile computing device, you must:

1. Obtain management approval via RFC.
2. Complete the RFC risk assessment questionnaire to ensure all details about the package being sent are documented, and security risks are noted and mitigated.

When sending such information by mail (including U.S. Postal Service, DHL, UPS, FedEx, etc.), the sender must obtain secure, certified, tracking and signature confirmation services and use a tamper-evident sealed package. It is highly recommended that obfuscation or encryption of the sensitive data items be done beforehand.

1. Do not send unencrypted sensitive information by mail or email.
2. When carrying unencrypted sensitive information, or devices containing such information, ensure that it is physically secure always.

Tape media containing sensitive data should be encrypted using an approved encryption method before being sent offsite. Where feasible, alternatives to mail delivery must be utilized such as a secured, encrypted online transmission. The transmissions that utilize passwords to encrypt or decrypt data must have their own unique identifier or password.