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GDPR Privacy Policy Template

Masha Komnenic CIPP/E, CIPM, CIPT, FIP

by Masha Komnenic CIPP/E, CIPM, CIPT, FIP

September 9, 2022

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When the EU’s General Data Protection Regulation (GDPR) was passed in 2016, it created several rules that businesses and website owners must comply with.

One of these rules was having a comprehensive and GDPR-compliant privacy policy to outline how they handle user data.

Below we’ll provide you with a free GDPR privacy policy template and go over what it includes and where you should post it on your site.

Table of Contents
  1. GDPR Privacy Policies Explained
  2. Does Your Business Need a GDPR-compliant Privacy Policy?
  3. What’s Inside a Privacy Policy That Complies With the GDPR?
  4. Where To Post Your GDPR Privacy Policy
  5. Good Examples of GDPR-compliant Privacy Policies
  6. Download Our Free GDPR Privacy Policy Template
  7. Summary

GDPR Privacy Policies Explained

The GDPR was enacted by the EU to protect the privacy and data of consumers and is intended to:

  • Protect website users from data breaches
  • Standardize data protection across all member countries
  • Create greater transparency for EU citizens to understand how their data is used
  • Allow users to easily opt out of data collection and file complaints when necessary
  • Develop strong protective measures for EU citizens regardless of where a business is located

The inclusion of a privacy policy on a business’s website is one of the many provisions covered by the GDPR.

Privacy policies are far from a new concept. They have been a part of business practices for decades, but the GDPR has specific requirements that have altered or expanded upon the policies that many organizations previously had in place.

While a GDPR-centric privacy policy should be customized for your business, there are certain standards it should meet, such as:

  • Written in clear and plain language that is easy for all users to understand
  • Concise and intelligible, leaving out unessential or distracting information
  • Transparent so that users know exactly how their data is being used and collected
  • Cost-free so that there are no impediments to access
  • Easily accessible so that users do not have to search in order to read it

Does Your Business Need a GDPR-compliant Privacy Policy?

The need for a privacy policy that complies with the GDPR is dependent on two factors: whether you collect personal data and whether you offer goods or services to any citizen within the EU.

While there are exceptions, a significant number of websites satisfy both of these requirements and, thus, need to have a GDPR-compliant privacy policy.

Even if you don’t realize that your business’s website collects data, it is your responsibility to comply, and you will be penalized if you fail to do so. Ignorance does not equate to a lack of accountability.

Never assume that your website does not collect customer information, and keep in mind that almost all websites collect at least some data through cookies. In general, your website collects data if it:

  • Is hosted by an outside company
  • Has plugins
  • Includes social media buttons
  • Utilizes analytics tools

If any of these attributes apply to your website, it is likely that you are collecting and processing customer data.

In addition to analyzing your website’s data collection, you will also need to consider your customer base.

There is sometimes a misconception that only businesses with headquarters within the EU need to comply with the GDPR. In reality, it is not the location of the business but rather the location of the customers that matters.

Businesses face severe penalties for failing to comply with the GDPR.

The maximum fine for a violation is 4% of a company’s annual global revenues or $22.8 million, whichever is greater. Initially, companies were fined at a relatively slow pace, but regulators have become more strict as time has passed. In fact, the year 2021 saw $1.2 billion in GDPR fines.

What’s Inside a Privacy Policy That Complies With the GDPR?

Fortunately, your business can avoid the costly penalties that result from a missing or insufficient privacy policy. The key to compliance is ensuring that you have included all the necessary information for your business or organization.

Contact Information

First, your policy must identify who is processing the customer’s data.

However, simply stating your name or the name of your business is not enough. You must also give a physical address or phone number and identify the data protection officer responsible for ensuring that all data is securely processed and stored.

Legal Basis

Your policy needs to include a legal justification for why your business is collecting data from consumers.

The GDPR has six legal bases for data collection:

  • Consent: The user has provided clear consent for data collection.
  • Contract: The collection of data is a necessary component of a contract between your business and the user.
  • Legal obligation: Your business is legally obligated to collect user data.
  • Vital interests: Data collection is necessary to protect human life.
  • Public task: Your business must collect data so that you can perform a task in the public interest.
  • Legitimate interests: Data is necessary for your business’s legitimate interests.

Although consent and legitimate interest are the most frequently used legal bases, you should base your selection on the structure and services provided by your business. Your privacy policy must clearly identify which basis or bases you have chosen.

You should use the official terminology laid out by the GDPR so that there is no mistaking your intention.

Purpose

In addition to the legal basis for processing data, your business must also articulate its purpose for collecting this specific information.

For example, you might use the data you collect to customize the user experience on your website. Or, you might use the data to verify a user’s identity, send messages or updates, or improve the website’s design.

The explanation of why your business needs data from consumers should be specific and detailed. Saying that you use data for personalization is much too broad. Instead, your policy should identify what is involved in this personalization.

At times, it’s prudent to include multiple purposes for different kinds of data. After all, you may collect home addresses for a different reason than the one for which you collect email addresses.

Data Collection, Use, and Transfer

Your business is obligated to explain not only why you are processing data but also how it will be collected, used, and transferred. As you outline your privacy policy, follow these steps:

  • Identify the method you use for collecting data, such as cookies.
  • Make clear whether you transfer the data internationally.
  • Indicate whether you will send the data to any third parties, no matter where they are located.
  • Disclose any automated decision-making, such as credit scoring, that involves customers’ data.

You might give each of these details a separate section within your business’s privacy policy. You can also incorporate them into a single section as long as they are well-defined and distinguishable.

Remember that addressing one of these points does not mean that you have achieved full compliance. In other words, if you reveal that you transfer information to third parties but do not divulge that those third parties are international, you have failed to comply with the GDPR.

Data Types

Consumers deserve to know not only that you are collecting their data but also exactly what information is being used. The GDPR’s definition of personal data is quite broad, so you may be processing more types than you realize.

Personal data essentially boils down to any information that clearly references a specific person. Depending on the context and the amount of data processed, this might include a user’s:

  • Date of birth
  • Social Security number
  • Phone number
  • Physical or email address
  • Personal description, such as eye color and weight
  • Workplace and education details
  • Religion
  • Political affiliation
  • Medical history
  • Genetic data
  • IP address

Much of this information on its own would not be enough to identify a particular individual. For instance, knowing a person’s religious beliefs does little to narrow down a pool of possible individuals. However, if you collect several types of data at once, such as the person’s religion, physical address, and date of birth, this may be enough for definitive identification.

Ultimately, it is your business’s responsibility to protect all personal data.

If you’re unsure of whether a certain piece of information falls into this category, it is best to be cautious. Include it in your privacy policy so that you avoid an accidental GDPR violation.

Data Storage and Security

The GDPR does not provide a specific limit on the amount of time for which your business can store a user’s data. However, that doesn’t mean you can keep your users’ data indefinitely.

The regulation states that businesses should store data for the shortest amount of time possible. Businesses may translate this as a set time span, such as three months or a year, or they may choose to keep the information as long as is necessary for tasks to be completed.

After that point, the data should be removed and the retention period that your business establishes must be included in your privacy policy.

In addition to explaining how long you will be storing personal data, it is also wise to identify the security measures that you have taken to protect it. This reassures your customers that you have their best interests at heart and prioritize their privacy.

Data Rights

The GDPR defines the eight rights of users. They must be listed in some form within your privacy policy so that customers are fully aware of what actions they can take with regard to their data:

  • The right to be informed of how their data is collected and processed
  • The right of access to any of their data that has been collected
  • The right of rectification to any inaccurate or incomplete data
  • The right to erasure of any and all data
  • The right to restrict processing to only certain types
  • The right to data portability so that data can be retained and reused for other purposes
  • The right to object to the use of their data for specific processing activities
  • Rights in relation to automation so that decisions are not made about the user based exclusively on automated processing

While listing these rights fulfills one aspect of the GDPR’s requirements, there is an additional step. Your privacy policy should also indicate the method by which these rights can be enacted.

You might provide a business phone number or a web form that can be used to make a specific data request.

Policy Changes

There will likely be times when you need to update your business’s privacy policy to accommodate changes in the company structure, the data you process, or how you use this data. One of the many possibilities is that, over time, you may incorporate a new feature into your site that requires information that you did not previously collect.

When you make changes to your privacy policy, it is important to promptly inform your website users.

You should be up front about the potential for changes and articulate the possibility within your privacy policy. Likewise, you should explain how users will be notified about policy changes, such as by email.

Where To Post Your GDPR Privacy Policy

The most important thing to consider when deciding where to include your privacy policy is whether it is easily accessible, which is a core requirement of the GDPR.

Inside Current Legal Policies

You should add a link to your privacy policy from your current legal policies or terms and conditions. If you choose to link to your privacy policy from these documents, make sure that it is clearly labeled.

Informational Menus or Sections

Another logical place to include a link to your business’s privacy policy is in the website’s informational menu or sections, particularly those that relate to the history or background of your organization. In many cases, a business has an “About Us” section that includes a reference and a link to the privacy policy.

Website Footer

Website footers are the most common location for privacy policies, and they’re often the first place a customer looks when seeking such policies.

Including a clearly labeled privacy policy link at the bottom of the webpage helps it stand out and makes it easier for customers to locate and identify the policy. However, scrolling to the bottom of certain websites is impractical, in which case it may be better to include the link elsewhere.

Banners and Pop-Ups

If you want to ensure that your site’s visitors do not miss the privacy policy, you can create a pop-up or banner that appears at a specific point during a customer’s interaction with the site.

During Sign-Up

Many business websites include an opportunity to sign up for a mailing list, a newsletter, or a free download like an e-book. Your organization’s privacy policy should be included in the process of signing up because this is a point at which many users are asked to provide personal data.

During Checkout

Similarly, you might include your privacy policy during the checkout process. Checkout, by nature, requires the disclosure of personal information like a person’s name, address, email address, and phone number. It is, therefore, highly appropriate to provide a direct reference to your privacy policy on your site’s checkout screen.

Good Examples of GDPR-compliant Privacy Policies

One of the best ways to know how to create a strong privacy policy is to look at examples from other businesses. However, do not be tempted to simply copy and paste a policy for your own business. The details in your privacy policy will differ from those of other companies, and copying could lead to a compliance failure.

Meta

meta-privacy-policy

Facebook Inc. was recently converted to Meta Platforms, which owns some of the world’s biggest companies, including Instagram, Messenger, and WhatsApp. As a result, Meta has created an extensive new privacy policy.

Meta’s policy is especially effective because the information is clearly organized, with a table of contents on the left for quick access. It also offers the information in multiple formats, with much of the policy described in short videos as well as text.

Many sections of the policy include direct links to the corresponding pages within Meta’s products, particularly Facebook.

For example, the section of the policy devoted to how information is shared offers a link to the specific locations on Facebook and Instagram where users can change the information that they have shared with third-party apps and websites.

Finally, Meta’s policy complies with the GDPR by including all of the necessary sections, creating a transparent experience for users.

Instacart

instacart-privacy-policy

While Instacart’s privacy policy is less aesthetically pleasing than Meta’s, it is clearly organized. In particular, Instacart is specific when describing how information is used and shared.

The policy also includes direct links so that users can exercise their rights to have information changed, deleted, or corrected, which is a critical component of the GDPR.

Target

target-privacy-policy

The privacy policy for Target has convenient links at the top of the page so that customers can jump to specific topics. This is an important feature because the policy is incredibly detailed, which could otherwise present challenges in locating specific information and, thus, violate the GDPR’s requirement for clarity.

Target’s policy is also an excellent example of a policy with distinctions under each section. For example, there are separate subheaders for each method of data collection, such as social media widgets, mobile location information, and cameras.

Stripe

stripe-privacy-policy

The privacy policy on Stripe’s website satisfies the GDPR’s requirement for using clear, direct, and intelligible language that can be easily understood by all users. The first section of the policy includes definitions for many of the terms used, which prevents confusion from arising later on.

To clearly align with GDPR requirements, Stripe specifically labels sections for legal bases, rights, security and retention, and international data transfers.

Download Our Free GDPR Privacy Policy Template

Expand the box below to view our sample GDPR privacy policy template in its entirety, or click the button to download the sample in Microsoft Word and PDF formats.

Both template formats can be easily added to the HTML of your site.

GDPR-Compliant Privacy Policy Template [Sample Text]

INTRODUCTION

Thank you for choosing to be part of our community at [business name] (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [contact email].

When you visit our website [website] (“Site”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain

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GDPR-Compliant Privacy Policy Template [Sample Text]

INTRODUCTION

Thank you for choosing to be part of our community at [business name] (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [contact email].

When you visit our website [website] (“Site”) and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our site and our services.

This privacy policy applies to all information collected through our websites (such as [INSERT URL]), [our mobile] [or] [our Facebook applications] (“Apps”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

This privacy policy was created using Termly’s Privacy Policy Generator.

Table of contents
WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
DO WE USE GOOGLE MAPS?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.

We collect personal information that you voluntarily provide to us when [registering at the Sites or Apps,] expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites [(such as posting messages in our online forums or entering competitions, contests or giveaways)] or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

[DN: INCLUDE IF USING SOCIAL MEDIA INTEGRATIONS] Social Media Login Data. We provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called “Social Logins” [LINK] below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information.  This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. [You can find out more about this in our Cookies Policy [Hyperlink]].

[DN: FOR MOBILE OR FACEBOOK APPLICATION ONLY:

Information collected through our Apps
In Short: We may collect information regarding your geo-location, mobile device, push notifications, and Facebook permissions when you use our apps.

If you use our Apps, we may also collect the following information:

Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s [Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.]

[Facebook Permissions. We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference ]

Information collected from other Sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

[DN: INCLUDE AS APPLICABLE TO THE SITE]

To facilitate account creation and logon process [with your Consent]. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “Social Logins” for further information.

To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.  You can opt-out of our marketing emails at any time (see the “Your Privacy Rights” below).

To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

Fulfill and manage your orders [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.

To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at [INSERT CONTACT] and be sure to include your name, testimonial location, and contact information.

Deliver targeted advertising to you [for our Business Purposes and/or with your Consent]. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. [For more information, see our Cookie Policy [HYPERLINK]].

Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use your information to administer prize draws and competitions when you elect to participate in competitions.

Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.

To protect our Sites [for Business Purposes and/or Legal Reasons].  We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).

To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user’s consent.

To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].

To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. [See our Cookie Policy [Hyperlink] for further information]

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

With your Consent. We may disclose your personal information for any other purpose with your consent.

Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site [or App], such personal information may be viewed by all users and may be publicly distributed outside the Site [and our App] in perpetuity. [If you interact with other users of our Sites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.]  Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.

[FOR MOBILE APPLICATION ONLY:

Offer Wall. Our Apps may display a third-party hosted “offer wall.”  Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer.  Such an offer wall may appear in our mobile application and be displayed to you based on certain data, such as your geographic area or demographic information.  When you click on an offer wall, you will leave our mobile application.  A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.]

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy [HYPERLINK TO POLICY].

DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. [By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). [We will be collecting the following information:     ]  (information list)

For a full list of what we use information for, please see the previous sections titled “Use of Your Information” and “Disclosure of Your Information.” [You agree to allow us to obtain or cache your location. You may revoke your consent at anytime.] [We use information about location in conjunction with data from other data providers.]

[The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, please take a look at our EU User Consent Policy, which can be found at this link: [link from question].]

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Sites offers you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. [If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.]

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in [INSERT DETAILS]. If you are accessing our Sites from outside [INSERT LOCATION OF SERVERS], please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “Disclosure of Your Information” above), in [INSERT DETAILS OF DESTINATION COUNTRIES] and other countries .

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

Option 1: European Commission’s Standard Contractual Clauses (use this if you choose model clauses as a ground for international transfers): Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. [Our Standard Contractual Clauses can be provided upon request / are available here [link]]. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

OR

Option 2: EU-U.S. Privacy Shield Framework (use this if you choose the Privacy shield framework as a ground for international transfers:

In particular [COMPANY] complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, [COMPANY] is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

[COMPANY] is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, [COMPANY] is subject to the regulatory enforcement powers of the U.S. FTC. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

OR

Option 3: Binding Corporate Rules (use this if you choose to implement Binding Corporate Rules):

These include, a set of Binding Corporate Rules (“BCRs”) established and implemented by [COMPANY]. Our BCRs have been recognized by EEA data protection authorities as providing an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here [INSERT LINK].]

WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than [90 days/6 months/1 year/2 years/the period of time in which you have an account with us/90 days past the termination of your account/6 months past the termination of your account/1 year past the termination of your account/2 years past the termination of your account].

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age.  By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site [and App].  If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data we have collected from children under age 18, please contact us at [INSERT CONTACT EMAIL].

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: [In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.] You may review, change, or terminate your account at any time.

[In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.  These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below [HYPERLINK]. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm] ]

[Account Information
You may at any time review or change the information in your account or terminate your account by:

Logging into your account settings and updating your account
Contacting us using the contact information provided below
[Other]
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.]

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. To opt-out of interest-based advertising by advertisers on our Site visit http://www.aboutads.info/choices/. [For further information, please see our Cookie Policy [HYPERLINK]]

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by:

Noting your preferences at the time you register your account with the Sites.
Logging into your account settings and updating your preferences.
Contacting us using the contact information provided below

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the [Sites/ Mobile Application/ Facebook Application], you have the right to request removal of unwanted data that you publicly post on the [Sites/ Mobile Application/ Facebook Application]. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.  We will make sure the data is not publicly displayed on the [Sites/ Mobile Application/ Facebook Application], but please be aware that the data may not be completely or comprehensively removed from our systems.

DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, email us [Our Privacy Officer] at [INSERT CONTACT EMAIL] or by post to:

[Company Name]

[PRIVACY OFFICER]

[Street Address]

[City, State Zip]

[If you are a resident in the European Economic Area, the “data controller” of your personal information is [INSERT NAME OF THE COMPANY]. [COMPANY, has appointed [INSERT NAME] to be its representative in the EEA. You can contact them directly regarding the processing of your information by COMPANY, by email at [INSERT CONTACT EMAIL] or by post to: [INSERT ADDRESS].]

If you have any further questions or comments about us or our policies, email us at [CONTACT EMAIL] or contact us by post at:

Company address

[Street Address]

[City, State Zip]

Summary

Creating a privacy policy with all of the necessary information is an important step toward ensuring that your business is complying with the GDPR and other privacy laws.

If your business offers any services or goods to EU citizens, it is essential that you comply with the GDPR. Using our GDPR privacy policy template is free and helps you verify that you have addressed all of the required points to achieve full compliance.

Remember that your privacy policy must be clear and easy for users to understand. Even a policy that addresses every point of the GDPR could lead to violations if it is too general, vague, or complex.

Masha Komnenic CIPP/E, CIPM, CIPT, FIP
More about the author

Written by Masha Komnenic CIPP/E, CIPM, CIPT, FIP

Masha is an Information Security and Data Privacy Specialist and a Certified Data Protection Officer. She has been a Data Protection Officer for the past six years, helping small and medium-sized enterprises achieve legal compliance. She has also been a privacy compliance mentor to many international business accelerators. She specializes... More about the author

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