By using our services, you understand and agree that we are providing a platform for you to post content, including data, text, files, information, usernames, images, graphics, photos, profiles, audio and video clips, sounds, musical works, works of authorship, applications, links and other content or materials (collectively, "Content"), to the Service and to share your Content publicly.
Our Policy applies to all visitors, users, and others who access the Service ("Users").
Information We Collect:
- Information you provide us directly:
- Your username, password and e-mail address when you register for a MemberWire account.
- Your Content (e.g., images, graphics, photos, profiles, audio and video clips, sounds, musical works, works of authorship, and other content or materials) that you post to the Service.
- Communications between you and MemberWire. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical, news and information, and security notices). Note that you may not opt-out of Service-related e-mails.
- If you choose to open a creator account (as opposed to a standard user account), you will additionally provide to MemberWire:
- Profile information that you provide for your user profile. This information allows us to help you or others be "found" on MemberWire.
- If you choose to post sexually explicit content, then you will additionally provide to MemberWire:
- Your full name, including any stage names or prior names;
- Your postal address;
- Your date of birth;
- A copy of your official government photo ID; and
- Analytics information:
- We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
- Cookies and similar technologies:
- All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
- Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Razr Tech S.A.R.L-S to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
- This Website may place the following Cookies:
|Type of Cookie
|Strictly necessary cookies
||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
||These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
||These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- You can find a list of Cookies that we use in the Cookies Schedule.
- You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser.
- You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
- It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
- For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.,
- Logfile information:
- LogfileLogfile information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page. It can also be provided when the content of the webpage is downloaded to your browser or device.
- When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users, which then help us track which emails are opened and which recipients click links. The information allows for more accurate reporting and improvement of the Service.
- Metadata is data that is associated with your Content. For example, Metadata can describe how, when and by whom a piece of your Content was collected and how that content is formatted.
- Financial Information:
- If a Creator account wishes to withdraw money from their MemberWire account, the Creator can choose to have that accomplished through a bank transfer. If a bank transfer is requested, the user will be required to provide the banking information necessary to complete this transfer. This banking information is not used by MemberWire for any purposes other than completing this transfer request.
- DO NOT PROVIDE SPECIAL CATEGORIES OF PERSONAL DATA:
How We Use Your Information:
- verify your identity at user login;
- remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
- communicate with you via email to send a welcome email, assist with password recovery, provide automated system emails, and provide news or other information about the Service;
- provide, improve, test, and monitor the effectiveness of our Service;
- develop and test new products and features;
- monitor metrics such as total number of visitors, traffic, and demographic patterns; and
- diagnose or fix technology problems.
Sharing of Your Information:
- We will not rent, sell, or share your information with third parties outside MemberWire, including marketing and advertising companies, without your consent.
- We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organisations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- We may remove parts of data that can identify you and share anonymised data with other parties. We may also combine your information with additional information in a way that it is no longer associated with you and share that aggregated information.
- Any information or Content that you voluntarily disclose for posting to the Service, such as your Content, becomes available to the public and other users of MemberWire.
- Suppose you remove information that you posted to the Service. In that case, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Service have copied or saved that information.
What Happens in the Event of a Change of Control:
Responding to Legal Requests and Preventing Harm:
- We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Luxembourg, where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognised standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
How We Store Your Information:
- Your information collected through the Service may be stored and processed in Luxembourg or any other country in which MemberWire or Service Providers maintain facilities.
- MemberWire or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction, to other countries or jurisdictions worldwide. If you are located in the United States or other regions with laws governing data collection and use that may differ from EU law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.,
- We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, MemberWire cannot ensure the security of any information you transmit to MemberWire or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. In the event that any personal information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.
- Some of the examples of the data security controls in place at MemberWire (this is not an exhaustive list):
- The use of encryption when personal data is transferred to MemberWire’s servers;
- Limited access to personal data by MemberWire staff on a need-to-know basis and the use of robust authentication processes;
- The use of data centres with effective physical and logical data security controls and the use of reputable third parties who have demonstrated security consciousness; and
- Secure office premises and staff that are aware of their data protection responsibilities.
- You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and MemberWire, at all times.
Your Choices About Your Information:
- We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
- You have the following rights, which you can request from MemberWire at any time:
- To stop processing your personal information on a temporary basis;
- The right to be forgotten (deleted from our servers);
- The right to object to processing; and
- The right to access, change or correct your personal information.
- Email firstname.lastname@example.org should you wish to exercise any of the rights above.
- Following termination or deactivation of your account, MemberWire or its Service Providers may retain information (including your profile information) and your Content for a commercially reasonable time for backup, archival, and/or audit purposes. Unless you contact us to delete your personal information, MemberWire will only retain your personal information for the period necessary to fulfil the purposes outlined in this Policy, but in no event longer than 6 months, unless a more extended retention period is required by law.
- MemberWire does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Service. The Service and its content are not directed at anyone under the age of 18. In the event that we learn that we have collected personal information from a child under age 18 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at email@example.com.
Other Websites and Services:
The Existence of Automated Decision-Making, Including Profiling:
- MemberWire does not take any decisions involving the use of algorithms or profiling that significantly affects you.
How to Contact MemberWire:
- If you are unsatisfied with the reply you receive from MemberWire, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
- If at any time in the future we plan to share personal information with more third parties, MemberWire will maintain GDPR compliance and a high standard of care for your personal information.
Additional Privacy Information for Residents of the European Economic Area:
- MemberWire has taken important steps for compliance with the General Data Protection Regulation 2018 (GDPR) for EU users. As a data controller, MemberWire understands our obligations under the GDPR (EU) 2016/679 and has taken the following steps:
- Appointed a MemberWire Data Protection Officer who can respond to EU data subjects and Data Protection Authorities as needed;
- Introduced new product features and functionality to allow users better control over their privacy;
- Reviewed our data inventory and third party relationships to gain a complete picture of data flows and take a Privacy by Design approach to our data holdings;
- Enhanced our data security controls such that regardless of the data flow, reasonable efforts are made to protect our user data at all times;
- Developed a procedure to respond to any requests that may be received from users who are EU residents regarding their subject data rights;
- Reviewed and revised our data retention rules to ensure MemberWire is not retaining personal information that is no longer in use;
- Required our third parties who we entrust with MemberWire user data to commit to the continued protection of such data and comply with the GDPR responsibilities as a data processor; and
- Instituted a privacy data breach response plan to ensure any privacy incidents are handled effectively and efficiently.
- Controller: MemberWire (Razr Tech SARL-S) is a private company established in Luxembourg. Our address is 9 Avenue des Hauts-Fourneaux, 4362 Esch-sur-Alzette, Luxembourg and our contact email address is firstname.lastname@example.org. For the purposes of the GDPR, we are the data controller.
- Legal Basis: We describe in the section above “How we use your information” the purposes for which we use the data collected and shared. Where we are using the data in order to provide MemberWire’s services to you, our legal basis for such use is on the basis of our contract with you. For all other purposes, our legal basis is our legitimate interest in running our business, including ensuring MemberWire’s Service functions properly and improving and creating new products and services except where we obtain your consent for particular processing. In this event, the legal basis will be your consent.
- Your Rights: To exercise any of these rights, please contact us at email@example.com. Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or where we are required by law to retain your personal data.
- Access and portability: You are entitled to request access to the personal information we hold and be provided with certain information about how we use your personal information and who we share it with. You have provided your personal data to us with your consent, you have the right to ask us for a copy of this data in a structured, machine-readable format and ask us to share (port) this data with another data controller.
- Correction: You have the right to ask us to correct your personal data where it is inaccurate or incomplete.
- Right to deletion: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
- Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data.
- Objection: You can object to our processing of your personal data based on our legitimate interests, and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
- Withdrawal of consent: In the event we have relied upon your consent to process your personal data, you may withdraw consent at any time by contacting us at firstname.lastname@example.org.
- Cease use: Finally, you may permanently, cease using MemberWire’s Service, and you may deactivate your account. After a reasonable time following such deactivation, as set forth above, MemberWire would no longer have access to your personal information.
- Complaints: In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at email@example.com, and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with relevant supervisory authority.
- Dispute Resolution platform: You may also use the online dispute resolution (ODR) platform to resolve the dispute with us. For more details, please visit the website on the ‘Your Europe’ portal: Better Business Bureau website http://www.bbb.org