Effective from January 1, 2021
1. Please read carefully.
2. What Personal Information do we collect
2.1. User Information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
Information you provide us. When you register for our Services, purchase and/or use any of our Services; and/or when you contact us directly by any communication channel, you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
2.2. Users of Users Personal Information
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. Why do We collect such Personal information
We use your Personal Information for the following purposes:
To provide and operate the Services;
.To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To help us to update, expand and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To analyze our performance and marketing activities;
To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
To provide you with professional assistance , only upon your request;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in Section 3 where:
Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with our customer assistance and technical support);
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of erbn' by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. How we share your Personal Information
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: we have partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
erbn' may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
commercial information, for example information regarding products or services purchased, obtained, or considered
4.1. The Personal Information may be shared solely in accordance with this policy.
Law Enforcement, Legal Requests and Duties: erbn' may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
4.2. Protecting Rights and Safety: erbn' may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of us, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
4.3.Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.
Users and Users-of-Users; collection, processing and use of your Information and it will be transferred to and processed by Wix on erbn' behalf.
4.6. Connection With a Change in Corporate Control: In addition, should erbn' or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
4.7.Upon Your Further Direction: erbn' may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
5. Where do we store your Personal Information?
Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the United States of America, Ireland, Japan and Israel. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.
Wix affiliates and Third-Party Service Providers that store or process your Personal Information on erbn's behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
5.1. erbn's data storage providers are contractually committed to protect and secure your data.
Transfer of EU Personal data : If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place.
5.2. Among other things, erbn' will ensure that there is the adequate level of protection or that relevant Model Standard Contractual Clauses are in place for the international transfer of our EU users’ data.
In compliance with the Privacy Shield Principles, erbn' commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: firstname.lastname@example.org For the avoidance of doubt, erbn' does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data.
erbn' has further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider at https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services are provided at no cost to you.
6. Users’ Personal Information
erbn' may collect, store and process certain Personal Information of Users (“Users-of-Users Information”), solely on erbn’s behalf and at our direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via our Website. Such contacts are then stored with Wix, on the erbn's behalf.
For such purposes, Wix serves and shall be considered as a “Processor”
The Processing of the Users Personal Information shall take place within the territory of the European Union, Israel or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Agreement – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be undertaken in accordance with the the Standard Contractual Clauses (2010/87/EU) set out in Annex 1of the DPA. For the sake of clarity, “Processing” should be understood as per the definition provided in the DPA.
erbn' responsible for the security, integrity and authorized usage of Personal Information about Users’
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8. Communications from erbn'
8.1. Promotional Messages
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from erbn' or our partners (acting on erbn’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify erbn' at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
8.2. Service and Billing Messages
erbn' may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding our website; or notify you of material changes in our Services.
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
9. Additional Information for California residents
If you are a California resident using the Services, the California Consumer Privacy Act (“CCPA”) may provide you the right to request access to and deletion of your Personal Information.
erbn' does not sell user Personal Information to third parties for the intents and purposes of the CCPA.
10. Questions and Complaints
Our team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.
11. Data Retention
We may retain your Personal Information for as long as needed to provide you with our Services.
We may continue to retain your Personal Information after you cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.
erbn' has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by erbn', we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other information you upload, publish or otherwise share with erbn' or anyone else. We encourage you to avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others, and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at email@example.com
13. Third-Party Websites
14. Public forums and user content
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information from such areas.
In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
We have put adequate security measures in place to protect your Personal Information. You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
15. Updates and interpretation
16. Contacting us
You may also contact us by mail at:
20 Florence St #61 Marlborough, MA 01752