100% Digital Agency cares deeply about the privacy of its visitors and users, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
We collect two types of information regarding our Visitors and Users:
Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying 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.
Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
We may also collect similar 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).
There are two main methods we use:
1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, edit your User Website and upload information and content, and/or download and use any 100% Digital Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you place purchases and/or register domain names; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., emails, support tickets).
3. We also collect information from third party sources as described in Section 8 below.
We collect such Non-personal and Personal Information for the following purposes:
1. To provide and operate the Services;
2. To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
3. To provide our Users with ongoing customer assistance and technical support;
4. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 10 below);
5. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
6. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
7. To enhance our data security and fraud prevention capabilities;
8. To consider Applicants’ candidacy for working at 100% Digital (as further detailed in Section 7 below); and
9. To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
1. our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support), or
2. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have, or
3. our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of 100% Digital campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
100% Digital Agency Visitors’, 100% Digital Agency Users’ and Users-of-Users’ Personal Information may be stored in data centers located at EU, and the United States of America. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below) and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law (as further explained below).
100% Digital Agency Jobs Applicants Information will be maintained, processed and stored in EU, in the applied position’s location(s), and as necessary, in secured cloud storage provided by our Third Party Services.
100% Digital Agency is based in EU, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
100% Digital Agency affiliates and service providers that store or process your Personal Information on 100% Digital Agency’s behalf are each 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.
Upon request 100% Digital Agency will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your 100% Digital Agency account erases all of your information from 100% Digital Agency’s databases. After completing this process, you can no longer use any of your 100% Digital Agency Services, your User Account and all its data will be removed permanently, and 100% Digital Agency will not be able to restore your account or retrieve your data in the future. If you contact 100% Digital Agency Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
Data Localisation Obligations: If you reside in a jurisdiction that imposes “data localisation” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere.
100% Digital Agency may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their 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 their User Website. Such contacts are then stored with 100% Digital Agency, on the User’s behalf.
For such purposes, 100% Digital Agency serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions. Subject to applicable law, 100% Digital Agency will process your User-of-Users Information in accordance with the Data Processing Agreement located here.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
100% Digital Agency cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
For more information on how Users-of-Users Information may be handled by 100% Digital Agency (which may be relevant for the specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 8, 13 and 14 below.
If you are a visitor, user or customer of any of our Users, please read the following: 100% Digital Agency has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by 100% Digital Agency on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 13 below.
100% Digital Agency welcomes all qualified Applicants to apply to any of the open positions published at https://project.100digital.agency/, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for 100% Digital Agency’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that 100% Digital Agency may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at 100% Digital Agency; so we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at 100% Digital Agency.
If you previously submitted your Applicants Information to 100% Digital Agency, and now wish to access it, update it or have it deleted from 100% Digital Agency’s systems, please contact us at [email protected]
100% Digital Agency may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
100% Digital Agency has 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, domain name registrars, 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(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
100% Digital Agency is accountable for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, 100% Digital Agency remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the Personal Information on its behalf do so in a manner inconsistent with the Principles, unless 100% Digital Agency proves that it is not responsible for the event giving rise to the damage.
Where permitted by local data protection laws, 100% Digital Agency may disclose or otherwise allow others 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 good faith belief that the law requires us to do so, with or without notice to you.
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect 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 Services 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 too are governed by such third parties’ policies and not ours.
As part of our App Market program, we allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the 100% Digital Agency App Market (“Third Party App(s)”), in conjunction with 100% Digital Agency.
In order to further protect your and your Users-of-Users’ privacy, we contractually prohibit all Third Party Developers from combining Personal Information collected across different User Websites and Services, and from sharing Users-of-Users’ Personal Information other than with other Apps installed on the same User Website or Services, for the purposes of such specific User Website or Services. 100% Digital Agency however may still access and use information collected and stored across different User Websites and Apps, as necessary for providing and improving its Services.
You are solely responsible for notifying your Users-of-Users of the collection, processing and use of their Personal Information and informing them that their Personal Information will be transferred to and processed by 100% Digital Agency on your behalf.
To prevent the collection or sharing of Personal Information, you may either avoid installing Apps to your User Website, revoke the permissions granted to Apps you do install, or simply uninstall them. You should note however that previously-installed Apps may still retain certain information that was collected prior to the revocation, so if you wish such information to be deleted, we suggest that you contact 100% Digital Agency or the Third Party Developer directly and request them to do so.
In addition, should 100% Digital Agency 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. If we have good faith that such change in control might materially affect your Personal Information stored with us, we will notify you via e-mail and/or prominent notice on our Website of this event and certain choices you may have regarding your Personal Information.
100% Digital Agency may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so. Moreover, 100% Digital Agency may transfer, share, disclose or otherwise use Non-personal Information in its sole discretion and without the need for further approval.
100% Digital Agency, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at https://www.aboutcookies.org/ (note that this website is not provided by 100% Digital Agency, and we, therefore, cannot ensure its accuracy, completeness or availability).
Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by 100% Digital Agency, and we therefore cannot ensure its accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website, on 100% Digital Agency Apps and on 100% Digital Agency mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: 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.
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, direct text messages, marketing calls and similar forms of communication from 100% Digital Agency or our partners (acting on 100% Digital Agency’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify 100% Digital Agency at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.
100% Digital Agency 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 for maintenance; 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 your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a 100% Digital Agency Visitor or User (which can be done by deactivating your account).
It is imperative that you have control over your Personal Information. That’s why 100% Digital Agency is taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a 100% Digital Agency Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, you are welcome to contact us at [email protected]
We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that permanently deleting your 100% Digital Agency account erases all of your information from 100% Digital Agency’s databases. After completing this process, you can no longer use any of your 100% Digital Agency services, your account and all its data will be removed permanently, and 100% Digital Agency will not be able to restore your account or retrieve your data in the future. If you contact 100% Digital Agency Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
Our Data Protection Officer 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. Our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a complaint with your local supervisory authority for data protection.
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.
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any 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: [email protected] In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any information (or use any posting means to post information) you don’t wish to publicize on these platforms.
If you upload any User Content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). 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.
Any heading, caption or section title contained herein, and any explanation or summary, is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.