GDPR Privacy Policy



Last Updated: 3rd September, 2019

We respect Your privacy and are committed to protecting it through this GDPR Privacy Policy (the “GDPR Policy”). This GDPR Policy is designed to help You understand how We collect, use, disseminate, keep, safeguard, and disclose the information You provide to Us while accessing or using the Services. By accessing or using the services offered on the Sites (“Services”), You signify Your assent to this GDPR Policy. If You do not agree with this GDPR Policy, You shall not access or use the Services. We reserve the right, at Our sole discretion, to change, add, or remove portions of this GDPR Policy at any time by posting such changes to this page. Such changes will be effective upon posting. You must read this GDPR Policy carefully and consult it regularly.

This GDPR Policy applies to information We collect:

It does not apply to information collected by:

Please read this GDPR 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 the Sites or the Services. By accessing or using the Sites or the Services, You agree to this GDPR Policy and consent to Our collection, use, disclosure, retention, and protection of Your personal information as described in this GDPR Policy. We may change this GDPR Policy on one or more occasions.

1. Revisions to this GDPR Policy

We will consider Your continued use of the Sites or the Services after We make changes to this GDPR Policy as Your acceptance of the changes, so please check this GDPR Policy frequently for updates. We reserve the right to revise, amend, or modify this GDPR Policy and Our other policies and agreements at any time and in any manner. You should periodically check for any modifications to this GDPR Policy by re-visiting this web page and using the “refresh” button on Your browser as well as clearing Your web browser history. You should note the “Last Updated” date at the top of this GDPR Policy. If the “Last Updated” date remains unchanged after You have clicked the “refresh” button on Your browser, You may presume that no changes have been made since the last reading of the GDPR Policy. A changed “Last Updated” date indicates that this GDPR Policy has been updated or edited, and the updated or edited version supersedes any prior versions immediately upon posting.

2. Are Minors Welcome?

The Sites are intended only for persons (a) that are at least eighteen (18) years old, (b) who have reached the age of majority in Your jurisdiction, and (c) that have the legal capacity to agree to these terms and enter into this Agreement. We prohibit all persons who do not meet these age requirements from accessing the Sites. Minors must not access the Sites. We do not knowingly collect any information about children, minors, or anyone under the age of majority, nor do We knowingly market to children, minors, or anyone under eighteen (18) years old. If You are under eighteen (18) years old, You must not submit information to Us and must immediately leave the Sites.

3. What types of information does the Site collect about You and how is it collected?

The public data and information made available on the Sites is not collected from You or other users but is acquired from various sources of public data and records. This public data and information that is made available through the Sites was obtained solely by publicly-available data and record sources, and such data and information was not acquired via Your or other users' access of the Sites. We collect several types of information from and about You and other users, including information:

· by which You may be personally identified, including Your name, postal address, email address, telephone number, or any other information that We collect that is defined as personal or personally identifiable information under law (“personal information”);

· that is about You but individually does not identify You, including Your age, gender, location, and any other optional information You provide about Yourself; and

· about Your Internet connection, IP addresses, device ID, the equipment You use to access the Sites or the Services, and usage details.

We collect this information:

· Directly from You when You provide it to Us;

· Automatically as You navigate through the Sites or the Services through cookies, web beacons, and other tracking technologies; and

· From third parties, for example, Our business partners.

Information You Provide to Us

The information the Site collects on or through the Sites or the Services may include:

· Information that You provide by filling in forms associated with the Services, including information provided at the time of registering to use the Services, signing up for an account, requesting further services, or reporting a problem with the Services, such as Your social media username, password, and other access information;

· Records and copies of Your correspondence (including but not limited to email addresses), if You contact Us;

· Your responses to surveys that We might ask You to complete for research purposes;

· Details of transactions You carry out through the Sites or the Services and of the fulfillment of Your requests;

· Your search queries on the Sites; and

· Your social media accounts used in connection with the Services.

Information We Collect through Automatic Data Collection Technologies

As You navigate through and interact with the Sites or the Services, We may use automatic data collection technologies to collect certain information about Your equipment, browsing actions, and patterns, including:

· Details of Your activities associated with the Services, including traffic data, location data, logs, and other communication data and the resources that You access and use on the Services;

· Information about Your computer and Internet connection, including Your IP address, device ID, operating system, and browser type; and

· Information about Your mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, the device’s telephone number, Your mobile carrier, Your precise geographic location information, and other information described in this GDPR Policy.

The information We collect automatically is statistical data and does not include personal information, but We may keep it or associate it with personal information We collect in other ways or receive from third parties. It helps Us to improve and personalize the Services, including by allowing the Sites to:

· Estimate audience size and usage patterns on the Services;

· Store information about Your preferences, thus allowing the Sites to customize the Services according to Your individual interests;

· Speed up Your searches; and

· Recognize You when You return to the Services.

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

  • Cookies (or browser cookies) . A cookie is a small file placed on the hard drive of Your computer. Your browser stores cookies in a manner associated with each website You visit. We use cookies to enable Our servers to recognize Your browser and tell Us how and when You visit the Sites and use the Services. 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 the Sites. Unless You have adjusted Your browser setting so that it will refuse cookies, Our system will issue cookies when You direct Your browser to the Sites. If You want to learn more about cookies, please visit
  • Flash Cookies . Certain features of the Sites may use local stored objects (or Flash cookies) to collect and store information about Your preferences and navigation to, from, and on the Sites. 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, You can access Your Flash management tools from Adobe’s website .
  • Web Beacons . Pages of the Sites (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 Us, 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). If You want to learn more about web beacons, please visit .

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 that You provide to Us.

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Sites 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 the Sites. 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 third-party tracking technologies or how third parties use them. If You have any questions about an advertisement or other targeted content, You should contact the responsible provider directly.

Social Networks and Third-Party Plug-ins

The Services may include plugins from social networks and other third parties. An example of a plugin is the Facebook® “Like” button. Where legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if You do not click on the plugin. This information may include Your IP address, information about Your browser and device, and the address of the webpage You are visiting on the Services. Loading, using, or clicking the plugins may also place, read, and transmit cookies. These cookies may contain a unique identifier the social network or third party assigns You. The loading, functionality, and Your use of the plugins are governed by the privacy policy and terms of the party that provided the plugin.

4 . How We Use Your Information

We may use information that We collect about You or that You provide to Us, including any personal information:

· To present the Sites or the Services and their contents to You;

· To provide You with information, products, or services that You request from Us;

· To fulfill any other purpose for which You provide it;

· To provide You with notices about Your account;

· To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including but not limited to enforcement of the Terms of Service;

· To notify You about changes to the Services or any products or services We offer or provide through the Sites;

· To allow You to participate in any interactive features on the Services;

· To monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes;

· To investigate and prevent unauthorized access to the Services and other illegal activities;

· To personalize the Services’ content, features, or advertisements;

· To contact You about Our own and third parties’ goods and services that may be of interest to You;

· To allow Us to display advertisements to Our advertisers’ target audiences;

· In any other way We may describe when You provide the information; and

· For any other purpose with Your consent.

5. With Whom Do We Share Your Information?

We may disclose aggregated information about Our users, and information that does not identify any individual, without restriction.

We may disclose personal information that We collect or that You provide as described in this GDPR Policy:

· To Our subsidiaries and affiliates;

· To 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;

· To 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 Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about You or other users is among the assets transferred;

· If You have not opted out of these disclosures, to third parties that market their products or services to You 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; and

· To any other party with Your consent.

6. Special Cases

It is Our policy not to use or share the personal information about users in ways unrelated to those described in this GDPR Policy without also providing You an opportunity to opt out or otherwise prohibit such unrelated uses. However, We may disclose personal information, or information regarding Your use of the Services, for any reason if, in Our sole discretion, We believe that it is reasonable to do so, including:

i. To cooperate with law enforcement authorities, government agencies, and private-party litigants seeking information about You or other users to the extent required by applicable law, or if We are legally advised to do so; examples of such cooperation may include but are not limited to: lawful criminal, civil, or administrative process or discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process;

ii. To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service or other policies;

iii. To operate the Services properly; or

iv. To protect the rights, property, or safety of the Sites, other users, and the general public, including but not limited to disclosures for the purposes of fraud protection and credit risk reduction.

7. What choices do You have about how We use and disclose Your information?

We strive to provide You with choices about the personal information You provide to Us. We have created mechanisms to provide You with the following control over Your information:

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.

8. Do Not Track Policy

Do Not Track (“DNT”) is a privacy preference that You can set in Your browser. DNT is a way for You to inform websites and services that You do not want certain information about Your webpage visits collected over time and across websites or online services. We are committed to providing You with meaningful choices about the information We collect and that is why We provide You the ability to opt out. However, We do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit

9. Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for Users and can be found here:

We use Google AdSense Advertising on the Sites. Google, as a third-party vendor, uses cookies to serve ads on the Sites. Google's use of the DART cookie enables it to serve ads to You based on previous visits to the Sites and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network Privacy Policy.

We utilize Remarketing with Google AdSense, Google display network impression reporting, demographics and interests reporting, and DoubleClick platform integration. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to the Sites.

If You wish to opt out, users can set preferences for how Google advertises to You using the Google Ad settings page. Alternatively, You can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

10. International Users

This Policy is intended to cover collection of information on or through Our Site within Our home jurisdiction. Some countries may require stricter privacy policies than those described in this document. If You are visiting Our Site from such a country, please be aware that Your information may be transferred to, stored, and processed in the country where Our servers are located and Our central databases are operated. The data protection and other laws of Our home jurisdiction might not be as comprehensive as those in Your country. By using Our services, You understand that Your information may be transferred to Our facilities and those third parties with whom We share it as described in this Policy. When You provide personal information to Us through the services, You consent to the processing of Your data in, and the transfer of Your data to, Our home jurisdiction or any other country in which We or Our affiliates, subsidiaries, or service providers host these services.

11. Designated Data Protection Officer (DPO)

You may contact Our designated GDPR Officer who is based in the EU by emailing admin[at]grooby[dot]com.

12. Our Commitment to Data Security

We have implemented measures designed to secure Your personal information from accidental loss and from unauthorized access, use, change, and disclosure. All information You provide to Us is stored on its secure servers behind firewalls.

Warning: The transmission of information over 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 through the Sites or the Services. Any transmission of personal information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures used by Us.

13. Your California Privacy Rights

California Civil Code § 1798.83 permits users of the Sites that are California residents to request certain information about Our disclosure of personal information to third parties for their direct marketing purposes. To make this request, please contact us by email at admin[at]grooby[dot]com.

Further, if You are a California resident and would like to opt out from the disclosure of Your personal information to any third party for marketing purposes, please contact us by email at admin[at]grooby[dot]com. Please be advised that if You opt out from permitting Your personal information to be shared, You may still receive selected offers directly from Us in accordance with California law.

14. Links to Other Websites

The Sites may contain links to other websites. Please be aware that We are not responsible for the content or privacy practices of those other websites. We encourage Our users to be aware when they leave the Sites and to read the privacy statements of any other website that collects personally identifiable information.

15. No Third-Party Rights

This GDPR Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to You or other users of the Sites or the Services.

16. DMCA Takedown Requests

We voluntarily comply with the Digital Millennium Copyright Act (DMCA). If You reasonably believe that Your copyrighted work has been used or posted by a third party without Your consent, You may follow the instructions here on how to report it.

By submitting a copyright infringement notice or other communication (including communications about content stored on or transmitted through the Sites), You consent to have these communications forwarded to the person or entity who stored, transmitted, or linked to the content addressed by Your communication, to facilitate a prompt resolution. We reserve the right to forward DMCA infringement notices (including any personally identifying information contained in the notices) as submitted to Us without any deletions.

17. Contact Information

To ask questions or comment about this Privacy Policy or the practices described herein, You may contact Us at admin[at]grooby[dot]com.

© Walters Law Group (2019). All rights reserved