Privacy Policy

GoPhrazy Privacy Policy
Last Updated: December 23, 2021

GoPhrazy LTD (“GoPhrazy”) has adopted this Privacy Policy (“Privacy Policy”) to inform you that it collects personal data (hereinafter referred to as “Personally Identifiable Information” or “PII”) when you use its Service, as defined in our Terms of Service, and to explain how this information is processed. GoPhrazy has also adopted this Privacy Policy because it respects your privacy and believes that it should clearly and transparently disclose its privacy practices to you as the user. This Privacy Policy does not apply to third party websites or applications, and you visit third party sites and applications at your own risk, consistent with their privacy policies, if any. GoPhrazy may update and change this Privacy Policy, at which time it will update the date of this Privacy Policy. GoPhrazy will inform you about such updates by email and on its website.

GoPhrazy May Collect the Following Personally Identifiable Information (PII) from You

Personally Identifiable Information (“PII”) is information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single person. GoPhrazy collects PII from you only when you voluntarily provide it to us, such as your name and email address, and other information such as your MAC and/or IP Address and any other information you must provide in order to access or use the Service. This PII is necessary to provide you with GoPhrazy’s services; the legal basis for its processing is Article 6(1)(b) of Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”). GoPhrazy may collect this PII from you through various communication channels which you use to communicate with GoPhrazy or use GoPhrazy’s services, including, but not limited to, through website and emails.

Your computer, mobile device and browsing activities may also be stored through the use of third party tools as follows:

1. Google Analytics

1.1. GoPhrazy uses Google Analytics, a web analysis service by Google Inc. („Google“). Google Analytics uses so-called cookies, text files that are saved on your computer and allow an analysis of the website. The information on your usage of the website are collected by the cookie are usually transferred to and saved on a Google server in the U.S.

1.2. By order of the operator of the website Google will use the information to evaluate your usage of the website, to create reports about website activities and to provide further services related to the usage of the website and of the internet for the operator of the website. Your IP address, transmitted by Google Analytics from your browser, will not be merged with other data from Google.

1.3. You can block the storage of cookies via the settings of your browser, however, if you do so it is possible that you will not be able to use all functions of the website to the full extent. If, in addition to this, you want to prevent the collection of data created by cookies and related to your usage of the website (including your IP address) by Google as well as the processing of these data by Google, you can download and install the browser plugin TrackerBlock.

2. Cookies

2.1. GoPhrazy uses cookies to analyze the web traffic, to optimise services and contents of the website, to measure the effectiveness of sales campaigns and to promote the trust in and the security of GoPhrazy. Cookies are small text files that are stored on your computer by your internet browser. Most of the cookies will be deleted from your hard drive after ending your browser session (session cookies). Other cookies remain on your computer and ensure that GoPhrazy recognises your computer at your next visit in order to analyze your usage (permanent cookies).
2.2. You can prevent the usage of cookies by adjusting the setting of your browser to not accept new cookies, to point out new cookies or to delete all previously stored cookies. You can find support for changing your settings in the help function of your web browser or at www.allaboutcookies.org. Please note that some of the functions of the website are only available if you allow the usage of cookies. We recommend that you do not deactivate the cookie function.

3. Web beacons

3.1. Web beacons (or „pixel tags“/„clear GIFs“) are small (usually 1×1 pixel) transparent GIF images that can be hidden in other images, e.g., on the website or in emails.
3.2. Web beacons fulfil similar functions as cookies. They transmit your IP address, the URL of the visited website, the time when the web beacon was viewed, the browser type, and further cookie information as set before to a web server.
3.3. GoPhrazy only uses web beacons on the website and – under certain circumstances – in the newsletter. By using the technology, GoPhrazy can identify your computer and analyze the user’s behavior (e.g. response to advertising campaigns). This data is anonymous and not linked to personal data on your computer or to a database. Without your explicit consent, GoPhrazy will not use web beacons to collect personal data and/or transmit such data to third parties or marketing platforms.
3.4. You can block web beacons with tools like AdBlock Plus.

The legal basis for the processing of this PII is Article 6(1)(a) GDPR. The PII is not necessary to provide you with GoPhrazy’s services but some functions of GoPhrazy’s website are only available if you allow the usage of cookies.

GoPhrazy Uses this PII for Certain Purposes

GoPhrazy collects PII and processes and uses it to provide you with the Service, communicate with you, identify and fix problems with the Service, improve the Service, update you on changes to the Service, customize the Service to you, communicate with you concerning your Account, and, if applicable, to complete a transaction you initiated, including for any payment processing purposes. The legal basis is Article 6(1)(b) GDPR; the processing is necessary to provide you with GoPhrazy’s services.

GoPhrazy Stores Your PII in the Following Manner

GoPhrazy may store and process your information utilizing third party vendors or on servers in different jurisdictions worldwide, including onces outside of the country in which you live, to the extent necessary to provide you with the Service (Article 6(1)(b) GDPR). If GoPhrazyis using a vendor to provide the Service, all data storage by the vendor shall be consistent with this Privacy Policy.

GoPhrazy will delete the collected and stored data as required by law.

GoPhrazy uses reasonable and standard technology to prevent unauthorized disclosure of your PII.

GoPhrazy May Share your PII with Third Parties in the Following Circumstances

GoPhrazy may disclose or otherwise make available your PII to third parties where GoPhrazy has obtained your consent (Article 6(1)(a) GDPR); where disclosure or otherwise making available of your PII is necessary to provide you with the Service (Article 6 (1)(b) GDPR); where disclosure or otherwise making available of your PII is necessary to respond to requests by government authorities; where your PII is demanded by a court order or subpoena; or where disclosure otherwise making available of your PII is prescribed by law (Article 6(1)(c) GDPR).

Withdrawal of Consent

As far as you have consented to the processing of your personal data by GoPhrazy, you can withdraw your consent at any time. In this case please send an email to

privacy@gophrazy.com

or contact:

GoPhrazy LTD
20-22 Wenlock Rd
N1 7GU London
United Kingdom
Telephone: +44 (0)20 3514 2432

As far as you have registered for our newsletter, your consent will be recorded and it can be withdrawn in your user account on our website at any time. You can also cancel the newsletter at any time by clicking on the “unsubscribe” button in the newsletter. In this case your email address will be removed from the newsletter distribution list and the withdrawal of your consent will be registered in your user account.

California Privacy Rights

In addition to the rights described in this Privacy Policy, California residents also have the right to receive information that identifies any third party companies or individuals that GoPhrazy has shared your PII with in the previous calendar year, as well as a description of the categories of PII disclosed to that third party. Consistent with California Civil Code Section § 1798.83, you may obtain this information once a year and free of charge by contacting GoPhrazy at the address below.

Children’s Online Privacy Protection Policy

The Service are not intended for or directed to users under the age of 13, and GoPhrazy does not knowingly or intentionally collect PII from children under the age of 13. Where appropriate, GoPhrazy takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Service. If you are concerned that PII may have been inadvertently provided to or collected by GoPhrazy, please contact us immediately so appropriate steps may be taken to remove such information from GoPhrazy’s Service.

Controller of your PII, Requests and Complaints regarding your PII

You have the free right to information about the PII being processed by GoPhrazy and, where applicable, to rectification, erasure, restriction of processing, or data portability.

Please address all requests, questions and concerns regarding this Privacy Policy to the responsible controller of your PII:

GoPhrazy LTD
20-22 Wenlock Rd
N1 7GU London
United Kingdom
Telephone: (EU): +44 (0)20 3514 2432
E-mail: privacy@gophrazy.com

The contact email of GoPhrazy‘s data protection officer is: privacy@gophrazy.com

You also have the right to lodge a complaint with a supervisory authority, in particular in the EU member state where you live, work, or where the alleged infringement took place.