Privacy Policy

Thank you for visiting this website, a digital service presented to you by Brazilian Classified Ads-Achei DBA AcheiUSA Newspaper (We). Your privacy is important to us. As such, we provide this privacy policy (“Privacy Policy”) explaining our online information practices and the choices you can make about the way your information is collected and used by this digital service and among AcheiUSA affiliated and operated digital services, which includes any online or mobile websites, applications or digital services owned, operated or offered by, on behalf of, or in conjunction with AcheiUSA or its Affiliates, including any online or mobile website, application or digital service installation through which this Privacy Policy appears (each a “Service,” collectively the “Services”). “Users” are persons that use the Services.

1. The Information We Collect

We receive both information that is directly provided to us, such as personal information you provide when you visit the Services, and information that is passively or automatically collected from you, such as anonymous information collected from your browser or device. In this Privacy Policy, we refer to all of this as the “Information”.

1. Information You Provide To Us.At some Services, you can register, order products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters or text message alerts, or participate in one of our online forums or communities. In the course of these various offerings, we often seek to collect from you various forms of information, such as: name, address, e-mail address, telephone number, fax number and credit card information.

At some Services, you may also be able to submit Information about other people. For example, you might submit a person’s name and e-mail address to send an electronic greeting card and, if you order a gift online and want it sent directly to the recipient, you might submit the recipient’s name and address. This Information may include, for instance, a recipient’s name, address, e-mail address, and telephone number.

2. Information That is Passively or Automatically Collected.We, and our “Partners” who include AcheiUSA Affiliates, third party service providers, advertisers, advertising networks and platforms, agencies, and distribution or other partners may use automated means to collect various types of Information about you, your computer or other device used to access our Services. A representative, non-exhaustive list of the types of automatically collected information may include: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, browser settings, the web pages of the Services you have visited, Services visited before and after you visit a Service, the type of handheld or mobile device used to view the Service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on.

3. Geo-location Information.If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on other Services, when we work with a Partner such as a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

4. Information Collected By and From Social Media Services and Other Third Party Platforms.You also can engage with our content, such as video, games, applications, and other offerings, on or through social media services or other third party platforms, such as Facebook, or other third-party social media plug-ins, integrations and applications. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or “likes.” For a description on how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.

When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed, your game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on.

1. How We Use the Information

We, along with our Partners, may use the Information to:

1. provide and communicate with you about the Services or your account with us,
2. fulfill your requests regarding the Services, including without limitation requests for newsletters and notifications,
3. respond to your inquiries, and notify you if you have won a contest,
4. communicate with you about other products, programs or services that we believe may be of interest to you,
5. enforce the legal terms (including without limitation our policies and terms of service) that govern your use of our Services, and/or for the purposes for which you provided the Information,
6. provide technical support for the Services,
7. prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services,
8. protect the safety of our Users,
9. customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them,
10. perform analysis regarding how you use the Services or any part thereof,
11. send gifts, cards, invitations or emails if you use these services, to your designated recipients.

When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our Services, (3) contact you through the social media service or directly by sending you the latest news, special offerings, and rewards, and (4) enable you to share your experience and content via social media services. When you provide information about yourself to us through an application, through our Services, or on social media services or other third party platforms, it may be publicly viewed by other members of these services and we cannot prevent further use of the information by third parties.

We or a Partner may use “cookies” or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser.

Sometimes, we may associate cookies with the Information, including de-identified, “hashed,” or anonymous versions of Information you have provided (such as during registration), in order to send or help our Partners send ads and offers based on your presumed interests or demographic information.

We may combine any of the Information we collect, for any of the above purposes, and may sometimes enhance the Information with other information that we obtain from third party sources. Please also be aware that if you choose to submit Information or content for publication (e.g., a letter to our editors, comments sent to our contributors, a posting to a blog or a discussion board, or a video), we may publish that Information and content, along with other Information about you (such as your name, screen name or location). Likewise, if you register and create a profile with our Service, the screen name you select as well as other content you submit to your profile (e.g., photos, comments, video, reviews) will be displayed publicly on the Service, is searchable, can be found by third parties and may be reused and redistributed by us in our sole discretion. See our Terms of Use for details on our use of content you submit.

III. Information Sharing and Disclosure

We may disclose the Information as follows:

1. To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill orders and user requests; (f) handle payments; (g) host our Services, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support our Services.
2. In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request.
3. With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing our Services.
4. We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way.
5. We may share the Information with AcheiUSA Affiliates, so they can provide, improve and communicate with you about their own, or their marketing partners’ products and services.

6. We may share the Information with unaffiliated Partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you.

Please note that the Services covered by this Privacy Policy may offer content (e.g., contests, sweepstakes, promotions, games, applications, or social network integrations) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain information from their visitors. We have no control over these third parties’ use of this information, which is subject to their own privacy policies.

1. Cookies and Other User and Ad-Targeting Technologies.

We use cookies and other technologies both to provide our Services to you and to advertise to you. We also may work with Partners to help them advertise to you when you visit other websites or mobile applications, and to help them perform user analytics. These technologies may also be used to analyze how our Users interact with advertising on our Services and elsewhere, and more generally, to learn more about our Users and what services or offers you might prefer to receive. We describe some of these technologies below.

1. Cookies. To enhance your online experience, we and our Partners use “cookies”, “web beacons” or other tracking technologies. Cookies are text files placed in your computer’s browser to store your preferences. We use cookies or other tracking technologies to understand Service and Internet usage and to improve or customize the products, content, offerings, services or advertisements on our Services. For example, we may use cookies to personalize your experience at our Services (e.g., to recognize you by name when you return to a Service), save your password in password-protected areas, and enable you to use shopping carts on our Services. We also may use cookies or other tracking technologies to help us offer you products, content, offerings or services that may be of interest to you and to deliver relevant advertising when you visit this Service, an AcheiUSA Affiliate’s Service, or when you visit other websites or applications. We or a third party platform with whom we work may place or recognize a unique cookie on your browser to enable you to receive customized content, offers, services or advertisements on our Services or other sites. These cookies contain no information intended to identify you personally. The cookies may be associated with de-identified demographic or other data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider solely in hashed, non-human readable form.

We, our third party service providers, advertisers, advertising networks and platforms, agencies, or our Partners also may use cookies or other tracking technologies to manage and measure the performance of advertisements displayed. This also helps us, our service providers and Partners provide more relevant advertising.

2. Syncing Cookies and Identifiers. We may work with our Partners (for instance, third party ad platforms) to synchronize unique, anonymous identifiers (such as those associated with cookies) in order to match our Partners’ uniquely coded user identifiers to our own. We may do this, for instance, to enhance data points about a particular unique browser or device, and thus enable us or others to send ads that are more relevant, match Users to their likely product interests, or better synchronize, cap, or optimize advertising.
3. Locally Stored Objects. Services may employ locally stored objects (“LSOs”) and other client side storage tracking technologies in certain situations where they help to provide a better user experience, such as to remember settings, preferences and usage similar to browser cookies, or in order to target or help our Partners target ads, analyze ad performance, or perform user, website or market analytics. For LSOs utilized by Adobe Flash you can access Flash management tools from Adobe’s website. In addition, some, but not all browsers, provide the ability to remove LSOs, sometimes within cookie and privacy settings.
4. Disabling Cookies

Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of the Services may be difficult to use or inoperable.

We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our Services. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising or to opt-out of this type of advertising by those third parties that are members of DAA’s opt-out program, please go to http://www.aboutads.info.

5. Web Beacons. We and our Partners may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).
6. Mobile Device Identifiers and SDKs.

We also sometimes use, or partner with publishers, publisher-facing, or app developer platforms that use mobile Software Development Kits (“SDKs”), or use an SDK with a mobile app that we offer, to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), and Information connected to how mobile devices interact with our Services and those using our Services. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services or analytics to be performed. We may use this technology to deliver or help our Partners deliver certain advertising through mobile applications and browsers based on information associated with your mobile device. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions in the “Your Ad Choices” section below.

By visiting the Service, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Service through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.

Our unaffiliated Partners and third parties may themselves set and access their own tracking technologies when you visit our Services and they may have access to information about you and your online activities over time and across different websites or applications when you use the Service. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.

1. Your Ad Choices

Advertising enables us to provide the rich content for which Services on AcheiUSA are known, and to provide much of this content free of cost to our Users. Thus, we strive to provide you with ads that are relevant to you and for products you may want.

However, we also offer you choices with regard to interest-based ads.

You may also find more information about entities involved in online advertising and additional choices you may make through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice Service.

The tools provided on the Ad Choices page, as well as the DAA opt-out page and the NAI opt-out page are provided by third parties, not AcheiUSA. AcheiUSA does not control or operate these tools or the choices that advertisers and others provide through these tools.

When using a mobile application you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device’s advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

1. Other Important Information About Your Privacy
2. How We Respond to Do Not Track Signals

At this time Services on AcheiUSA do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions.

2. Linked Services

Some of the Services contain links to or integrations with other services such as Facebook, Twitter, LinkedIn, and other media services and platforms whose information practices may be different than ours. Visitors should consult these other services’ privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

3. International Transfer

This Service is governed by and operated in accordance with US law. If you are located outside of the US, you use this Service at your own risk. AcheiUSA is a company that operates globally so it is necessary to transfer your Information internationally. In particular, your Information will be transferred to and processed in the United States where many of our central databases operate. By using this Service, you (a) acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country, and consent to your Information being collected, processed and transferred as set forth in this Privacy Policy and US law.

4. Data Security

We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store.

Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

5. How You Can Access or Correct Information

Access to certain personal Information that is collected from our Services and that we maintain may be available to you. For example, if you created a password-protected account within our Service, you can access that account to review the Information you provided.

You may also send an e-mail or letter to the following e-mail or street address requesting access to or correction of your personal Information. Please include your registration information for such service such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

E-mail Administration

AcheiUSA Newspaper

Attention: Privacy Policy Coordinator

2001 West Sample Road, Suite 422

Deerfield Beach, FL 33064

email: info@acheiusa.com

6. How to Contact Us/Opting Out of Marketing Communications

If you have any questions or concerns about the online Privacy Policy for this Service or its implementation, or if you would like to opt out from our sharing of your personal Information with unaffiliated third parties for the third parties’ direct marketing purposes you may contact our Privacy Policy Coordinator at the above address and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

If you have signed up to receive our e-mails and prefer not to receive marketing information from this Service, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from this Service. If you have signed up to receive text messages from us and no longer wish to receive such messages, you may follow the instructions to stop the delivery of such messages, which may include by replying “STOP” to the received text message.

7. California Residents — Your California Privacy Rights

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.

VII. Updates & Effective Date

From time to time, we may update this Privacy Policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and with whom we share it.

Privacy Policy Update

Last updated: May 23 2018

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of our products or services after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this Privacy Statement, you may cancel your use or service.

General Introduction to this Privacy Policy

The controller of personal information in relation to this privacy policy is Brazilian Classified Ads-Achei DBA AcheiUSA – 816 SE 9th Street Suite E, Deerfield Beach, FL 33441, PH +1 (954) 570-7568.

This policy explains the types of information that we may collect and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries, concerns or complaints about this information. Some of our services also have their own privacy policy which provide details of the use of your information by that service. Where applicable, these service-specific policies may apply in addition to or instead of this policy.

Data protection principles

All processing of personal data by AcheiUSA group company is conducted in accordance with the data protection principles as set out in data protection laws and regulations in Article 5 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereafter referred to as the “GDPR”).

These principles are:

• Lawfulness – We only process your information when we have identified a lawful basis for the intended personal data processing pursuant to Article 6 of the GDPR. These are often referred to as the “conditions for processing”, for example contractual or legal obligation, legitimate interest or explicit consent.
• Fairness – We have made reasonable effort to ensure not to use your data in any unjustified way or in a manner which may have adverse effects on our users, as well as kept to minimum in order to provide users with qualitative products and services.
• Transparency – We have made our best efforts to provide you detailed information on AcheiUSA’s use of your personal information. Our users and visitors are encouraged to contact us whenever they have questions or seek information about our privacy procedures.

Our policies and procedures are to our best efforts designed to ensure compliance with these principles.

1.COLLECTION AND USE OF YOUR PERSONAL INFORMATION

AcheiUSA may collect personal information about you in several different ways. Personal information in this context is any and all data relating to a natural person that can be used, directly or indirectly, to identify a natural person, (e.g. name, contact details, identification number, location data etc.).

Please take care when submitting personal information to us, in particular when completing free text fields. Some of our services are automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.

AcheiUSA’s processing of your personal information is conditioned predominantly on the basis of legal obligations under law, contractual obligation to provide you our products and services, and your legitimate interest of us providing you product and service information, updates, news on latest product developments and/or other information which may enhance your musical and sound experiences.

1.1.Information that you provide us or that is collected

You may be asked to provide your personal information anytime you are in contact with AcheiUSA. For example:

• When you create a user account, purchase a product, place an advertisement, or use a product or service, AcheiUSA may collect a variety of information; including your name, mailing address, phone number, e-mail address and contact preferences.
• When you submit your contact details to participate in surveys or to receive marketing materials and promotions, we ask you for your name, age and contact details such as email address.
• When you interact with our user support centres, we may keep information about the interaction, including your name, the product(s) you purchased, the reason why you contacted us and the advice we gave you.
• When you use our online services, we may receive content that you choose to upload, such as reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive.
• When you join one of our loyalty programs, we may collect information relating to your use of the loyalty program and the rewards that you claim.
• When you visit us at a public event, such as trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for information, such as your business card, name, contact details, interests and preferences.

Some of our online services and websites collect and provide us personal information about your use of them, including:

• Details of the online content viewed with and interact with, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket.
• Services, products or server logs, storing information about your use of our services, products or websites, such as your IP address, browser information (including HTTP user agent strings), HTTP client request information and the time and location of your activities, domain, device and application settings, errors and hardware activity.
• Information about your hardware’s physical location, geo-location service or application.
• Interests and preferences that you specify when setting up your browser, account, or other Internet enabled product or services.

In general, such online information is collected using digital identifiers such as browser cookies, plugins or your IP address. These identifiers are used to distinguish the information provided by your hardware or browser that you use. However, we may associate the collected information with one of your accounts, if for instance you are logged into our services when the information is collected.

1.2.Information we may collect from other sources

AcheiUSA may also collect personal information from publicly available sources and third parties, including:

• When purchasing our products or services, we may carry out credit and financial checks to ensure payment is not made fraudulently and that you have a suitable credit rating.

1.3.Information we may collect in relation to social networks

If you use any of AcheiUSA’s social network applications, pages or plugins or you use one of our products or services that interacts with social networks, we may process personal information from your social network accounts, such as:

• If you log-in to one of our websites or services using your social network account, we may receive basic details from your social network profile, based on your social network account privacy settings, However, we may receive information such as your social network ID, name, profile picture, gender and geographic location. Depending on your social account permission settings, we may also grant us access to additional personal information from your social network profile.
• If you click on social network functions such as “likes”, “+1”, “tweet” or similar buttons in one of our websites or services, we may receive, record and profile your social network activity related to our products and services, depending on your social network privacy settings. Please take note that the content that you view may be posted to your social network profile or feeds. We may receive information about your further interactions with such posted content (e.g., if your contacts click on a link in the posted content), which we may associate with the details that we store about you.

For more information and for details about how you can control or restrict access to your social network profile, you must review the relevant social network provider’s privacy policy and guidelines on privacy and data safety.

1.4.How AcheiUSA uses collected personal information

AcheiUSA uses the personal information it collects:

• To communicate with you and to send you important notices, such as information about purchases, support, security announcements and changes to our terms, conditions and policies.
• To operate and to improve its online and digital services, websites and its contents, as well as the products and how to enhance their user-friendliness.
• To provide you with the product or service you have requested or purchased, including checking that a payment is not made fraudulently.
• To enhance our product and service quality and to educate our personnel to ensure quality, compliance and social responsibility.
• To seek your input and opinions on AcheiUSA products and services, and to conduct surveys and collect user input about our products and services.
• To facilitate and process your searches, enquiries and requests for information when you contact us about our products and services.
• To keep you informed about new products and services and upcoming events, as well as to provide you with newsletters and other sales and marketing communications from us or third parties.
• To monitor and enforce our user terms, policies and guidelines when you use AcheiUSA products, services or contents, as well as to prevent and to mitigate the risk of fraudulent use of such material.
• To create anonymous, aggregated statistics about the use of our website, products, services and other programmes, which we may share with third parties and/or make available to the public.
• To develop and improve new and existing AcheiUSA products and services, recommendations, advertisements and other communications.

You may at any time decide not to participate (opting-out) in our processing of your personal data by changing your AcheiUSA account settings or receiving specific instructions by email. If so, please take note that such opting-out may impact and restrict your use of our products and services. Notwithstanding, your privacy is of uttermost importance to us.

We may retain your information as long as it is necessary for us to fulfil the purposes outlined above or in this Policy. In addition, we may retain your information for an additional period as is permitted or required to, among other things, comply with our legal obligations, resolve disputes, and enforce agreements. Where and when required by applicable law, we shall delete your information. Please take note that certain personal information may remain on backup or storage media, even if we delete your information from active databases. However, we will take all reasonable efforts to ensure that such personal information remain confidential, protected (including anonymised) and not used for any other purposes than ensuring compliance with applicable laws and regulations.

1.5.Forums, blogs and AcheiUSA’s online information sharing sources

Each time you create or reply to a post or thread on a AcheiUSA website forum, blog, RSS or when you advertise on our classified section, in addition to providing such online services we may also record the forum, blog, RSS, advertisement or information sharing source name and the time and date of your post or thread with your account details. We do this to better understand our users, to provide user tools and guidance and to select or tailor our products, services, marketing communications to reflect your use activity. We do not use the content of such posts or threads for any other additional purposes.

1.6.Interlinking collected information

We may link or combine the information that we collect from the different sources outlined above (including information received from our partners and third-party developers). Information may be linked via a unique identifier, such as a cookie, plugin or other account identifiers. Alternatively, we may decide to combine two or more databases into a single database of user information.

We may do this for your and/or our convenience (for example, to allow you to more easily register for a new product or services), to allow us to provide a more seamless user support whenever you contact us and to provide you with qualitative, personalised services, content, marketing and adverts.

1.7.Marketing communications and subscriptions

When you provide us with contact details, such as when you sign-up on our website, or create an account, you may be given the opportunity to receiving newsletters, product information and other communications by email from AcheiUSA. These communications may include, e.g. details about our latest products, services, or events. We may also use your information to personalise and to target more effectively our marketing communications.

You can change your marketing communication preferences at any time by:

• changing your account settings;
• follow the “unsubscribe” link or instructions provided to you (typically at the bottom of an email or in connection to the place on the website where the information is collected); and/or
• sending a written request to unsubscribe directly to our user support centres.

Please take note that we may occasionally send you important information about our products and services that you are using or have used (such as order confirmations and service changes). These emails are not affected by your marketing communication preferences and/or subscriptions described above.

1.8.Children’s Privacy

Subject to AcheiUSA Terms of Service, you must be 18 years of age or older to subscribe and to use our products and services. However, AcheiUSA allows individuals under the age of 18 to utilise our products and service, but they may do so only with the involvement, supervision, and approval of a parent or legal guardian.

AcheiUSA considers a child to be anyone under the age of 18. We do not knowingly seek or collect personal information from or about children without the explicit consent of a parent or guardian.

If we become aware that personal information that has been submitted to us relates to a child without the consent of a parent or guardian, we will use reasonable efforts to:

• Delete that personal information from our files as soon as possible.
• Ensure, where deletion is not possible, that this personal information is not used further for any purpose, nor disclosed further to any third-party.

Any parent or guardian with queries and questions concerning personal data processing that may relate to their child should contact us by using the details provided in the “Contact us” section.

2.SHARING OF PERSONAL INFORMATION

2.1.Sharing your information with third parties

In general, AcheiUSA does not sell, rent, share or otherwise disclose your personal information with third parties. Notwithstanding, in our endeavour to provide you with quality products and services, we may need to make certain exemptions to this general principle (in particular when information about you cannot be transferred in anonymous and/or in pseudonymised form).

• We may disclose information about you to other AcheiUSA group companies. They may combine this information with other details they hold about you. Unless they provide you with their own privacy policy, they may use your personal details for the purposes explained in this policy.
• We may use third-party service providers to process information on our behalf for the purposes outlined above, e.g. to fulfil orders, delivering packages, sending postal mail and emails, providing marketing, technical and support assistance, processing credit card payments, providing IT and cyber security services, providing fraud checking services and providing customer services etc.
• We may disclose and use information about you with our third-party Developers to process information for the purpose of ensuring product compatibility and interlinkage with AcheiUSA products, modules and services to optimise your use of AcheiUSA products and services.
• If you request or agree to receive information or newsletters from one of our business partners, we may provide that third-party with your details so that they can respond to your request.

For research and statistical purposes, we prepare anonymous, aggregate or generic data (including “generic” statistics) for a number of purposes outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third-party (such as our partners, advertisers, industry bodies, the media and/or the general public). However, also in this we apply a restrictive approach in order to ensure a high level of security and safety.

Please take note that our third-party service providers, acting on our behalf, always operate only in accordance with our instructions, in line with this policy, and are subject to appropriate confidentiality, privacy and security obligations. However, other third-party providers, such as third-party developers, generally process shared information to develop and optimise their products and services. When using third-party developer products in AcheiUSA products and services, we recommend that you always read such third-party developer’s privacy policy and use terms before using their products or services in AcheiUSA products and services.

Additionally, we may also use and/or disclose information about you to:

• government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies;
• third parties (including professional advisors) to enforce or defend the legal rights of AcheiUSA group company or the terms and conditions of our products and services; and
• third-party investors, and theirs and our professional advisors, in connection with a corporate governance event such as a merger, business acquisition, tax or insolvency situation.

Finally, a number of our online and website services allow you to upload or share messages, photos, video and other content and links with others and/or create a publicly accessible profile for your account. For example:

• The communities and forums area of our website, allows you to post comments (with your account name), which are visible to other users of that service.
• Other services allow you to share a link which if clicked on may allow the recipient to access your uploaded content.

You should not expect any information that you make available to others via AcheiUSA’s online services to be kept private or confidential. Any information, contents or links that you may voluntarily share with others may be forwarded by the recipients to others. You should always exercise caution or discretion when using such online services, in particular when using social network applications.

2.2.Transfer of personal data outside of the EU/EEA

We are a global organisation and provide our products and services to users across the globe. For the purposes explained in this policy, your information may be transferred to our group companies (including service providers operating on our or their behalf) and other third parties in countries which may not have the same level of data protection laws as those in the country where you are located. Currently, we predominantly utilise third-party service providers, business partners and developers located in the United States of America.

3.INFORMATION SECURITY

3.1.How do we protect your information?

We have adopted and implemented a number of technical and administrative measures to protect your privacy from unauthorised access, use or alteration and unlawful destructions, including where appropriate the following steps:

• Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but AcheiUSA).
• Limiting access rights to the information we collect about you (e.g., only those of our personnel who need your information to carry out our business activities are allowed access to process your information).
• Implementing physical, digital and procedural safeguards in line with relevant business standards and guidelines.

3.2.What you should do to help us in protecting your information?

As general best practice on the Internet, it is recommended that users take great care with their accounts, and follow vigilantly some general safety rules:

• Do not press a link that you do not expect to receive or not requested by us to press.
• Do not use simple, trivial, or versatilely used passwords when creating an account or using our products and services.
• Do not share your account information with any person claiming to represent AcheiUSA. For support purposes, we only need you to provide us with the email address you used when creating your AcheiUSA account.
• Do install anti-virus, anti-phishing or anti-malware software on the hardware when using our products and services.
• Always contact us if you are unsure or in doubt of a communication received from AcheiUSA or a source claiming to be associated with us.
• Never use an unlicensed AcheiUSA account fraudulently created to access our products and services.

3.3.Cookies and other technologies

AcheiUSA may use technologies, such as cookies, to collect information about the pages you view, the links you click and other actions you take on AcheiUSA’s website and services. Cookies are small text files that are stored on your hard drive through your web browser.

AcheiUSA may use cookies in order to store your preferences and other information on your computer in order to save time by eliminating the need to repeatedly enter the same information, for example by remembering personal information when you use AcheiUSA’s websites, and to display your personalized content and targeted advertising on your later visits to its websites. However, the cookies used on AcheiUSA’s websites does not normally contain information that identifies you personally.

3.3.1.Cookies on AcheiUSA’s websites

AcheiUSA uses session cookies as well as persistent cookies on its websites. A session cookie is a temporary cookie which is erased when a session is ended, i.e. usually when you close your browser, while a persistent cookie is stored in one of your browsers subfolders until deleted manually or the set duration period of the persistent cookie expires.

AcheiUSA uses cookies such as “ph_hasloggedin” in order to determine whether to show “sign up” or “log in” when prompting a user to log in, “ph_st_variants” in order to determine which version of a page to show to a user, and “ph_sessionid” in order to remember information about a logged in user.

3.3.2.Third-party cookies on AcheiUSA’s websites

AcheiUSA also uses third-party cookies. Third-party cookies may be necessary in order for third parties to provide its services to AcheiUSA. AcheiUSA uses third-party cookies such as __ga in order to access Google Analytics data, and km_ai in order to access Kissmetrics data.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your settings to decline cookies as well as delete existing cookies from your device if you prefer. If you choose to decline and/or delete cookies, you may not be able to use all features of AcheiUSA websites or services that depend on cookies.

4.ACCESS TO YOUR INFORMATION AND YOUR RIGHTS

4.1.Your rights

AcheiUSA wishes to inform you that you, as a data subject, are entitled to exercise certain rights related to our processing of your information, e.g. you have the right:

• To request information on which personal data relating to you we collect, store, transfer or otherwise process, as well as for what purposes the information was processed and to whom it has been disclosed.
• To prevent us to process your information in a manner that is likely to cause damage or distress to you, or to process your information for direct marketing purposes.
• To be informed about the mechanics of automated decision-making processes that will significantly affect you.
• To seek compensation for any damages that you suffer by any contravention of our legal obligations under privacy and data protection laws applicable to us for processing your information.
• To call for action for us to rectify, block, erase, delete, or destroy inaccurate data that we process about you (including your legal right to be forgotten).
• To request the supervisory authority to assess whether we have processed your data in contravention of our legal obligations under privacy and data protection laws applicable to us.
• To request us to send you a copy of the information we store about you, and/or to have that data transmitted to another third-party.
• To object to any automated profiling that may occur without your knowledge or approval.

You can exercise these rights by contacting us using the details given in the “Contact us” section below.

Please take note that we may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks. Furthermore, we may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfil the purposes described in this Privacy Policy.

4.2.Your choices

If you no longer want to receive certain communications from us, simply access the settings pages in the “Your Account” section of our website and follow the instructions on how to subscribe. Alternatively, click the “unsubscribe” link in our communications (or as otherwise instructed). Please note that you cannot unsubscribe from certain email correspondence from us, such as messages relating to your account transactions, software updates and instructions.

Furthermore, please take note that a complete removal of your user account or your email address will result in you not being able to use our products or service.

To exercise choices regarding cookies set through our website, as well as other types of online tracking, see the “Cookies and other technologies” section above.

5.CONTACT US

If you need further assistance or would like to make a comment, you can contact us:

• Via our online web form.
• By sending a mail to AcheiUSA 2001 West Sample Rd, Suite 422 – Deerfield Beach, FL 33064 United States of America
• By telephone: +1 (954) 570-7568 (operating hours: 9 a.m. to 5 p.m, Monday to Friday).

The Privacy Policy posted on this Service was updated on May 23, 2018.