Privacy Policy

This SecretSanta.com Privacy Policy was last updated on August 31, 2018.

Our Policy:

Welcome to www.SecretSanta.com (together with its subdomains, the “Site”), the website of FYI Technology, Inc., a New York corporation (“SecretSanta.com”, “we”, “us” and/or “our”). The Site is operated by SecretSanta.com and has been created to provide you with information about SecretSanta.com and our social gift-giving services and related services (the “Services”). This Privacy Policy described how SecretSanta.com collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “Personal Data”) provided by users through the Site, as well as information collected by us through other means, including by email, over the phone, or in offline communications.

We take your privacy and the security of your information seriously.

This policy explains:
• What information we collect, and how we use it;
• Choices you can make about the way your information is collected and used;
• How we protect personal information electronically and physically.

This policy is incorporated into and a material term of your registration and/or use of SecretSanta.com’s products and Services, including the Site. By using the Site or Services, you consent to the practices set forth in this Privacy Policy.

Information We Collect:

When you interact with us through the Site or by using the Services, we may collect Personal Data and other information from you, as further described below.

Information You Provide:

We collect Personal Data and other information from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Site or use certain Services. The information we collect may include your name, address, email address, telephone or mobile phone number, and related information. You may be required to provide certain Personal Data and other information to register for and receive the Services.

By voluntarily providing us with Personal Data and other information, you are consenting to our use of it in accordance with this Privacy Policy, including the transfer of such Personal Data from your current location to the offices and servers of SecretSanta.com and the authorized third parties referred to in this Privacy Policy.

Information We Automatically Collect:

We may use cookies or other technologies to automatically collect certain information when you visit our Site or interact with the Services. For example, if you are responding to an offer, promotional email and/or other email from us, we may automatically populate your personal information into our system once you enter your offer code or similar identifying device or otherwise accept your offer or promotion. Additionally, we may automatically collect certain non-information from you such as your browser type, operating system, software version, and Internet Protocol (“IP”) address. We also may collect information about your use of the Site, including the date and time of access, the areas or pages that you visit, the amount of time you spend using the Site, the number of times you return, whether you open, forward, or click-through emails, and other Site usage data.

You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.

Use of Personal Data and Other Information:

SecretSanta.com uses the Personal Data and other information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Site or use the Services, we will use your Personal Data to provide you with access to the Site and the Services. SecretSanta.com may also use your Personal Data and other information collected through the Site and the Services to help us improve the content and functionality of the Site, to better understand our users and to improve the nature and quality of our Services. Subject to applicable law, SecretSanta.com may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Aggregated Personal Data:
In an ongoing effort to better understand and serve its users and customers, SecretSanta.com may conduct research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and SecretSanta.com may share this aggregate data with its affiliates, agents and business partners. This aggregate information will not identify you personally. SecretSanta.com may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Sharing of Personal Data and Other Information:

We consider your personal information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers & Partnership Agreements:
As we develop our business, we might sell or buy businesses or assets, or enter into partnerships with other businesses. In the event of a corporate sale, merger, reorganization, dissolution, partnership or similar event, Personal Data may be part of the assets transferred in such transaction.

Related Companies:
We may share your Personal Data with any of our corporate affiliates or subsidiaries, if any, for purposes consistent with this Privacy Policy.

Agents, Consultants and Third Party Service Providers:
SecretSanta.com, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we ensure that they are obligated to keep such information confidential.

Legal Requirements:
SecretSanta.com may disclose your Personal Data or other information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of SecretSanta.com, (iii) act in urgent circumstances to protect the personal safety of users of the Site, the Services or the public, or (iv) protect against legal liability.

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Children and Minors:

SecretSanta.com does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Site or through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to SecretSanta.com through the Site or the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites:

The Site may have links to third-party websites not operated or controlled by SecretSanta.com, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites, nor does any such link imply that SecretSanta.com endorses or has reviewed the third party site subject to such link. The policies and procedures we described here do not apply to the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Social Networking Services:

One of the special features of our Site and Service is that you may log in via various social networking services like Facebook or Twitter (“Social Networking Services”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission to access certain of your information via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of each such Social Networking Service, and SecretSanta.com shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within our Site or our Services.

You may also have the option of posting your Site or Services activities to Social Networking Services when you access content through the Site or the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

Data Security:

SecretSanta.com takes reasonable steps to protect the Personal Data and other information that you provide to us via the Site and the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to SecretSanta.com via the Internet.

INFORMATION FOR EEA USERS

What Rights Do I Have?
Individuals located in the European Economic Area (EEA) have certain rights in respect of your Personal Data, including the right of access, rectification, restriction, opposition, erasure and data portability. Where possible, we rely on user consent as a lawful basis for processing personal data and obtain such consent in compliance with applicable laws. In some cases, SecretSanta.com may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.

How May I Exercise My Individual Rights?
SecretSanta.com users may access and update their Personal Data through their account settings in the SecretSanta.com platform. Users located within the EEA may contact us with questions or requests regarding their Personal Data using the contact information below. Please note that SecretSanta.com may request additional information from you to verify your identity before we disclose any personal or account information. We only send marketing communications to users we believe to be located in the EEA with your prior consent, and you may opt out of such communications at any time by clicking the “unsubscribe” link found within SecretSanta.com email updates and changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails.

Who Can I Contact at SecretSanta.com Regarding Data Protection Issues?
SecretSanta.com has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him or her by emailing help@elfster.com and addressing your questions or concerns to the Data Protection Officer.

Other Terms and Conditions:

Your access to and use of the Site is subject to our Terms of Use, available at www.SecretSanta.com/terms-of-service/

Changes to This Privacy Policy:

The Site and the Services and our business may change from time to time. As a result, at times it may be necessary for SecretSanta.com to make changes to this Privacy Policy. SecretSanta.com reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting SecretSanta.com:

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Site or the Services.

Please also feel free to contact us if you have any questions about SecretSanta.com’s Privacy Policy or information practices.

You may contact us as follows: help@elfster.com