GDPR PRIVACY NOTICE
EGG Bytes Inc. (“Erin Gaulding”)
Effective Date: 18th April 2019
Controller Disclosure & Details: We are a data controller of personal data regarding the following categories of EEA Individuals: Visitors and Registered Users (collectively, “Customers”) and affiliate partners and vendor contacts (collectively, “Business Contacts”) for the purposes and under the legal bases described in the table below. Please note that, in some cases, the categories of data subjects above may overlap (e.g., Visitors and Registered Users using the Websites).
Data Subject Category Purpose & Legal Basis of Processing
General (applies to all data subjects below)
Information Security: Our web servers will log your IP address and other information (e.g., browser information, operating system, request date/time, user agent string, referral and exiting URL) in order to maintain an audit log of activities performed. We use this information pursuant to our legitimate interests in tracking usage of the Websites, combating DDOS or other attacks, and removing or defending against malicious visitors on the Websites.
Customers: Direct Marketing: Generally-speaking, we will provide email marketing (e.g., our newsletter) pursuant to a Customer’s consent. In cases where a Customer buys, or enters into negotiation for the sale of, a product or service, email marketing shall be sent to such Customer pursuant to our legitimate interest in sending marketing communications to such Customers in the context of a sale.
Rewards and Promotions: Erin Gaulding, our promotional and marketing partners (e.g., affiliate partners), and customers’ legitimate interest in administering our rewards and promotional offerings. For example, after purchasing a Erin Gaulding product or service, we share your name and email address with the referring affiliate partner only to the extent such affiliate partners have offered you bonuses or rewards for following their referral link.
Testimonials or Feedback: Our legitimate interest in using testimonials, feedback, or survey responses from Customers for marketing purposes, such as posting on the Websites or within sales decks, pitches, or other promotional content (e.g., email marketing).
General Business Development: Our legitimate interest in furthering business relationships (such as by storing Customer information within a CRM or other database/file), ensuring customer satisfaction, and answering inquiries.
Audience Measurement and Retargeting: Pursuant to a Visitor’s consent, we use an assortment of marketing and analytics cookies for purposes of audience measurement, retargeting, and creating relevant Visitor experiences (such as based on their interaction with our Websites).
Business Contacts: Affiliate Partners, we will process all personal data as necessary for the performance of contracts to which our affiliate partners are a party (e.g., our affiliate partner terms) or to take requested steps to enter into such contracts (e.g., completing our affiliate partner application).
Vendor Contacts: When entering into vendor relationships, we will receive the personal information of contacts employed or otherwise associated with such vendors. We process such information in our legitimate interest in establishing and developing our vendor relationships.
Categories of Recipients: Erin Gaulding personnel will process the categories of EEA Individuals’ (as listed above) information appropriately for sales, marketing, finance, and related purposes. Such EEA Individuals’ information (or a particular category of EEA Individual, as listed in the table above) is also disclosed to various categories of recipients to effectuate the purposes described in the table above, including companies providing technical assistance, order fulfillment, customer service, marketing assistance, payment processing, survey collection, promotional and marketing assistance, and business operations.
Retention: Erin Gaulding retains your personal data as necessary to fulfill the purposes set forth within this Notice and to the extent you have (or demonstrate interest in) a relationship with Erin Gaulding, unless you request deletion of such data or such data is no longer relevant. In some cases, we may have to retain data to comply with our legal obligations (e.g., accounting, finance, tax).
Your GDPR Rights: As a natural person, you have a right to: (i) request access to, correction and/or erasure of your personal data; (ii) object to processing of your personal data; (iii) restrict processing of your personal data; and (iv) request a copy of your personal data, or have a copy thereof sent to another controller, in a structured, commonly used and machine readable format under the right of data portability. You may exercise these rights and submit a GDPR complaint by contacting: firstname.lastname@example.org with the subject line “GDPR Notice.”
You also have the right to lodge a complaint about the processing of your personal data with an appropriate data protection authority, and, as applicable, to exercise third-party beneficiary rights under Erin Gaulding’s Standard Contractual Clauses.
Objecting to Legitimate Interest/Direct Marketing: You may object to personal data processed pursuant to our legitimate interest. In such case, we will no longer process your personal data unless we can demonstrate appropriate, overriding legitimate grounds for the processing or if needed for the establishment, exercise, or defense of legal claims. You may also object at any time to processing of your personal data for direct marketing purposes by clicking “Unsubscribe” within an automated marketing email or by submitting your request to email@example.com with the subject line “GDPR Notice” (the latter for instances where, for example, you would not like to receive follow-ups from our sales team). In such case, your personal data will no longer be used for that purpose.
Transfer of Personal Data outside the EEA: We are self-certified under the EU-US and Swiss-US Privacy Shield for appropriate transfer of your personal data, such as to our US data centers, pursuant to Article 45(1); in these instances, you may have specific rights under the Privacy Shield. In other instances, however, we may alternatively rely on appropriate Standard Contractual Clauses to ensure adequate protection for your personal data.
Disclosure to Public Authorities: Erin Gaulding may be required to disclose personal data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Corporate Restructuring: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal data, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal data as set forth in this GDPR Notice. This GDPR Notice shall be binding upon Erin Gaulding and its legal successors in interest.
Updates to this GDPR Notice: If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with information on that purpose and any other relevant information at a reasonable time prior to such processing. After such time, the relevant information relating to such processing activity will be revised or added appropriately within this GDPR Notice, and the “Effective Date” at the top of this page will be updated accordingly.
How to Contact Us: Please reach out to firstname.lastname@example.org for any questions, complaints, or requests regarding this GDPR Notice; please include the subject line “GDPR Notice.”