1. Services covered by this Policy
2. What personal information we collect from you
2.1. We may collect personal information (e.g., name, email address, mailing address, photos) from you through the Services in the ways discussed in this Policy. We may also receive your personal information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. If you refuse to divulge your personal information when requested, you may not be able to access certain areas as part of the Services (such as the ability to buy, sell products and services).
2.2. We may collect the physical location of your device in order to record and publish information on your position and to show you products offered by users close to you. InfoCities may collect this information by, for example, using satellite, cell phone tower or WiFi signals. In some instances, you may be permitted to allow or deny such collection and use of your device’s location, but it may affect the possibility of using the Services.
2.3 We may also use any ad you post on InfoCities, including the uploaded photo or image of the product as well as other data (including user name and location) associated with the ad, for our own advertising purposes, including social media, Facebook ads, newsletters and ads for any media.
2.4. We may use or disclose the personal information we collect from you as we believe necessary or appropriate, including, but not limited to, using and disclosing personal information for the following purposes: to protect people or property, to protect our services, rights or property, to comply with legal requirements, to respond to legal process or law enforcement requests and to comply with requests from other public and government authorities.
3. Memberships and Registration
3.1. To use the Services you need to register, either by providing us your e-mail address or your social media account. We may also collect information including phone number, birthday, and gender. In case you choose to register using a social media account, you authorize us to access and use certain information depending on the privacy settings that you have selected in the social network. Examples of personal data that we compile and use include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share.
3.2. We may require you to provide us information such as a profile picture, name and surname, user name and email address for purposes of making available that information on the App and on the Website. You may visit some areas of the Services as a guest and remain anonymous, but you may not be able to access all the content and features of those areas without registering.
4. Public information
4.1. Please note that any information you post or disclose through the Services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
4.2. Please note that your user name and your public photo will be available to the Internet's general public while you participate in some Services, such as publishing products, so you should exercise discretion when using the Services. Personal information disclosed by you may be collected by other users of such Services and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our Services (e.g. sending your telephone number to another user through the Services).
5. Email Newsletters and Push Notifications
We may contact you and/or send to you commercial communications via electronic communications, such as email, to inform about our products, services, offers, or any commercial content related to the company. If you do not want to receive marketing emails from us, you can always opt-out by following the unsubscribe instructions provided in such emails. Please note that even if you opt-out from receiving commercial communications, you may still receive administrative communications from InfoCities, such as transaction confirmations, notifications about your account activities (e.g. account confirmations, password changes, etc.), and any other important announcements. We may also send you push notifications if you have opted-in to receive them. You can disable push notifications in your mobile device’s settings.
6. What non-personal information we collect from you
6.1. In many cases, we will automatically collect certain non-personal information about your use of the Services. We collect this information to ensure that the Services function properly. We might collect, among other things, information about your browser or device, app usage data, information through cookies, pixel tags and other technologies, and aggregated information. This information may include:
- App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. We may also, on some versions of the App, collect information about other applications that you may have on your device (but not about the contents of those applications). We may also collect information collected automatically through your browser or device, or through the App when you download and use it. We may collect Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using.
- the operating system you are using, the domain name of your Internet service provider and your "click path" through the Sites or the App;
- IP address, which we may use for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address;
6.3. We may also collect non-personal information when you voluntarily provide it, such as your preferred method of communication.
6.4 We may aggregate \personal information, which when aggregated does not personally identify you or any other user of the Services. For example, we may aggregate personal information to calculate the percentage of our users who have a particular zip code.
6.5. We may use and disclose non-personal information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine this information with personal information. For example, if you have created an account with our Services, your account information may be linked to the items you purchased (i.e., purchase order history). If we do, we will treat the combined information as personal information as long as it is combined.
7. Information on cookies and related technology
7.1. InfoCities Services may contain "cookies."
8. How you may access, delete or change the information you have provided to us
8.1. You can exercise your rights to access, rectify, erase and object the processing of your personal data at any time by sending a writing request to InfoCities’s above mentioned address or to the following e-mail address: firstname.lastname@example.org.
8.2. In order to properly attend your request, please make clear what personal information you are writing about. For your protection, we may only respond to requests for the personal information associated with the email address you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as we can.
9. Our commitment to secure the personal information we have collected
We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. No website or Internet transmission is, however, completely secure. Consequently, InfoCities cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the App and Services is at your own risk. InfoCities urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place.
10. Third Parties
11. TRANSFER OF YOUR PERSONAL DATA
12. LEGAL BASIS FOR DATA PROCESSING
If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:
(i.) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
(ii.) If the processing of your personal data is necessary for the perfor-mance of a contract between you and InfoCities or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not processed, InfoCities will not be able to execute the contract with you.
(iii.) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of employment law.
(iv.) And where the processing is necessary for the purposes of InfoCities’s’ legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.
13. Notice of changes to the Policy
InfoCities reserves the right to modify this Policy at any time by notifying registered users via e-mail or the App of the existence of a new Policy and/or posting the new Policy on the Services. All changes to the Policy will be effective when posted, and your continued use of any InfoCities Services after the posting will constitute your acceptance of, and agreement to be bound by, those changes.
If you have any questions or comments regarding this Policy, please contact us by email contact@InfoCities.com or by mail at 3964 River mark Plaza, Suite 119, Santa Clara, CA 95054. Please do not send sensitive information to us by email, since email communications are not always secure.