The R Pages Privacy Policy

Updated October 1st, 2023

This Privacy Policy describes our policies on the collection, use, and disclosure of information about you in connection with your use of our services, including those offered through our websites, communications (e.g., emails, phone calls, and texts), and mobile applications (collectively, the “Service”). The terms “we”, “us”, and “The R Pages” refer to: The R Pages a LLC Business and all people that works for the company.

When you use the Service, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy.

1. INFORMATION WE COLLECT AND HOW WE USE IT

We may collect, transmit, and store information about you in connection with your use of the Service, including any information you send to or through the Service. We use that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, provide feedback to third party businesses that are listed on the Service, display relevant advertising, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.

Please also note:

A. Account Information: When you create a The R Pages account, we store and use the information you provide during that process, such as the first and last name you enter, email address, zip code, physical address, and any other information you may provide during the account creation process, such as a gender, phone number, or birth date. We may publicly display the first name and last initial that you provide, as well as any photo or other content you submit through the account creation process, as part of your account profile. We also store and use any preferences you provide to personalize your user experience, including dining and activity preferences. If you believe that someone has created an unauthorized account using your personal information, you can request its removal by calling us on the phone number displayed on the website.

B. Public Content: Your contributions to the Service are intended for public consumption and are therefore viewable by the public, including your photos, ratings, reviews, tips, lists, Collections, compliments, Ask the Community posts, and edits to business page information. Your account profile (e.g., first name, last initial, city, neighborhood, the month and year you created you’re the R Pages account, profile photos) is also intended for public consumption, as is some of your other activity through the Service, like how you vote on other people’s contributions (e.g., useful, funny, cool, helpful, or not helpful), which contributions you like, where you check-in.

C. Contacts: You can invite others to join or become your friend on The R Pages by providing us with their contact information, or by allowing us to access contacts from your computer, mobile device, or third-party sites to select which individuals you want to invite. If you allow us to access your contacts, we will transmit information about your contacts to our servers long enough to process your invitations.

D. Communications: When you sign up for an account or use certain features, you are opting to receive messages from other users, businesses, and The R Pages. If you exchange messages with others through the Service, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests to exchange reviews for compensation. If you send or receive messages through the Service via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on The R Pages, or use a phone number associated now or previously with such a business, we may contact you, including by phone or email, using the contact information you provide us, make publicly available, or that we have on record for your business. Our communications with you, including phone calls, may be monitored and recorded for quality purposes.

E. Transactions: If you initiate a transaction through the Service, such as a reservation or purchase, we will collect and store information you provide associated with your transaction, such as your name, phone number, address, email, and payment information, as well as any other information you provide, in order to process your transaction, send communications about the transaction to you, and facilitate future transactions. This information may be shared with third parties, and third parties may share such information with us, for the same purposes. When you submit credit card numbers and other sensitive payment information, that information is encrypted using industry standard technology. If you write reviews about businesses with which you transact through the Service, we may publicly display the fact that you transacted with those businesses in connection with such reviews

F. Activity: We store information about your use of the Service, such as your search activity, the pages you view, the date and time of your visits, businesses you call using our mobile applications, and reservations, purchases, or transactions you make through the Service. We also store information that your computer or mobile device may provide to us in connection with your use of the Service, such as your browser type, type of computer or mobile device, browser language, IP address, WiFi information such as SSID, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs and mobile applications. We may also receive and store your location whenever our mobile applications are running, including when running in the background, if you enable our mobile apps to access such information in the course of using the Service. You may be able to limit or disallow our use of certain location data through your device or browser settings, for example by adjusting the settings for our applications in iOS or Android privacy settings.

G. Different Devices: You may access the Service through different devices (e.g., your mobile phone or personal computer) and different platforms. The information that we collect and store through those different uses may be cross-referenced and combined, and your contributions through one The R Pages platform will typically be similarly visible and accessible through all other The R Pages platforms.

H. Professional Information: If you represent a business on The R Pages, we may collect and display information about you related to your business activities, such as a business name that may incorporate your name, or a publicly available business address that is also used as a home address. We will also collect and display information about your professional background that you choose to share with us through the Service, such as information about your professional licenses or certifications, or your professional history or specialties.

2. COOKIES

We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s Identifier for Advertisers (“IDFA”) or Google’s Advertising ID (“GAID”)) and similar technology (“Cookies”) in connection with your use of the Service, third party websites, and mobile applications. Cookies may contain unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have interacted with, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

The purposes for which we use Cookies in the Service include:

• • Processes: Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.
  • Authentication, Security, and Compliance: Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.
  • Preferences: Intended to remember information about how you prefer the Service to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications to your phone.
  • Notifications: Intended to allow or prevent notices of information or options that we think could improve your use of the Service. For example, we use a Cookie that stops us from showing you the signup notification if you have already seen it.
  • Advertising: Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently interacted with an ad.
  • Analytics: Intended to help us understand how visitors use the Service. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Service. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

3.THIRD PARTIES

Third parties may receive information about you as follows:

A. Advertisers: We allow third parties to use Cookies through the Service to collect the same type of information for the same purposes as we do. In doing so, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Third-parties may be able to associate the information they collect with other information they have about you from other sources. Please note that opting out does not prevent the display of all advertisements to you. We may also share some non-identifiable, de-identified or aggregated information from or about you, such as location information, with third parties in connection with advertising programs and data analytics. You may be able to limit our sharing of some of this information through your mobile device settings, as described in Section 2 above, or through the Service’s settings.

B. Content Partners: We allow third party partners to use and display some of the public content available through the Service, such as your photos, reviews, and other information listed under “Public Content” in Section 1 above.

C. Service Providers: We rely on third party service providers to support or provide services for us in connection with your use of the Service, such as food delivery services, communications and hosting, security and fraud prevention, technical and customer support, tracking and reporting usage of the Service, quality assurance testing, payment processing, marketing, and other functions. We share information from or about you with these third party providers so that they can perform their services or complete your requests. For example, we may share your advertising identifiers (e.g., your IDFA, GAID, or a cryptographic hash of your email address) with third party service providers that help us facilitate The R Pages’s advertising programs and measure and report their effectiveness, including with third parties that help determine the efficacy of The R Pages’s advertising programs by combining information they receive about you from other sources than the Service. You may be able to limit our access to some of this information through your mobile device settings, as described in Section 2 above, or through the Service’s settings. The R Pages’s third party service providers may likewise share information with us that they obtain from or about you in connection with providing their services or completing your requests.

D. Aggregate or Anonymous Information: We share user information in the aggregate with third parties, such as businesses that are listed on The R Pages and content distributors. For example, we disclose the number of users that have been exposed to or interacted with advertisements, or that we believe visited the physical location of a particular business.

E. Business Transfers: We share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, and require them to also honor this Privacy Policy. If another company acquires The R Pages, or all or substantially all our assets, that company will possess the same information, and will collect, use, and disclose the information only as described in this Privacy Policy.

F. Businesses on The R Pages: We may share information from or about you (such as your city, and if you provide it, your age and gender), your device type, and your use of the Service (such as which businesses you bookmark or call, or if you visit a business’s URL) with businesses on The R Pages. Keep in mind that businesses can also view your public activity and posts, and may receive information from or about you when you transact or communicate with them, through The R Pages or otherwise, regardless of your settings (see Section 1 above). Additionally, if you make a phone call to a business through or in connection with your use of the Service, we may share information about your call with the business that the business would have received had you called them directly, such as the date and time of your call and your phone number. You may be able to limit our ability to collect and share your phone number through your phone settings or phone service provider.

G. Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with legal or law enforcement processes, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement request; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public, such as disclosures in connection with The R Pages Consumer Alerts program. If you flag or otherwise complain to us about content through the Service, we may share the substance of your complaint with the contributor of that content in order to provide an opportunity for the contributor to respond.

H. Links: The Service may link to third-party controlled websites, like a business’s URL. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices.

I. Third-Party Integrations: If you sign up for, or log into, The R Pages using a third party service like Facebook or Google, or link your The R Pages account to your account with a third party service like Facebook, Instagram or Twitter, we may receive information about you from such third party service. If you post content to a third party service through the Service, that third party service will also receive that content, which will be visible to anyone that has access to it through that third party service. Some of our web pages utilize framing techniques to serve content to you from our third party partners, while preserving the look and feel of the Service. In such cases, please note that the information you provide may be transmitted directly to the identified third party partner. If you interact with businesses through The R Pages, they will receive whatever information you choose to share with them, for example contact information you share through direct messages to the business or your phone number if you call the business.

2. CONTROLLING YOUR PERSONAL DATA

Other users may be able to identify you, or associate you with your account, if you include personal information in the content you post publicly. You can reduce the risk of being personally identified by using the Service pseudonymously, though doing so could detract from the credibility of your contributions to the Service. Please also note that the messages you send or receive using the Service are only private to the extent that both you and the recipient(s) of your messages keep them private. For example, if you send a message to another user, that user may choose to publicly post it. We may access, review, and disclose such messages in connection with investigations related to use of the Service, as well as our efforts to improve the Service.

3. DATA RETENTION AND ACCOUNT TERMINATION

You can close your account anytime. We will remove certain public posts from view and/or dissociate them from your account profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. We may also maintain residual copies of your personal information in our backup systems. Please note that businesses cannot remove their business pages, ratings, or reviews by closing their accounts.

4. CHILDREN

The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us immediately. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account.

5. SECURITY

We use various safeguards to protect the personal information submitted to us, both during transmission and after we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

6. CONTACT INFORMATION

You may contact us by phone call or email concerning our Privacy Policy

For security purposes, we will take such steps as we deem necessary to confirm your identity before completing your request or sharing any personal data with you.

7. MODIFICATIONS TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Service prior to or on the effective date of the changes. By continuing to access or use the Service after those changes become effective, you acknowledge the revised Privacy Policy.

8. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around The R Pages’ collection, use, and sharing of their personal information.

The R Pages does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

The R Pages collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information The R Pages collects and how we use it is provided above in Section 1 (Information We Collect and How We Use It). Section 3 (Third Parties) describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information.

You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow The R Pages to retain and use certain personal information notwithstanding your deletion request.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above in Section 8.

9. NEVADA RESIDENTS: YOUR NEVADA PRIVACY RIGHTS

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. The R Pages does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.

The R Pages Geo Location Privacy Policy

Updated Setember 18th, 2023

This Privacy Policy describes the privacy practices of MaxMind, Inc. (sometimes referred to in this Privacy Policy as "MaxMind", "we", or "us"), in connection with the MaxMind.com website (the "Website") and the geoip-js.com website, any features and online services provided by MaxMind that post or include a link to this Privacy Policy, and communications with us (collectively, the "Services").
Please read this Privacy Policy carefully. By visiting and using the Services, you agree that your use of the Services is governed by this Privacy Policy. In addition to our Privacy Policy, your use of the Services is governed by our Terms of Use, which govern in the event of any conflict with this Privacy Policy.

1. SCOPE OF PRIVACY POLICY

This Privacy Policy applies to the MaxMind.com website, any features and online or offline services provided by MaxMind that post or make available a link to this Privacy Policy, and communications with us (such as phone calls, emails, and webform submissions to us). It does not apply to MaxMind's services that MaxMind's customers may use on their own websites, to other companies' or organizations' sites to which we link, or to companies that MaxMind does not own or control, even if such companies are contractors or business partners of MaxMind.
This Privacy Policy also does not cover how MaxMind customers may treat your information as the use of your information by such parties is governed by the privacy policies of such parties and is not subject to MaxMind's control.
You may have additional rights based on your jurisdiction. Please visit the relevant section below for details:

• California (Section 12)
• Nevada (Section 13)
• Virginia (Section 14)
• Europe and the United Kingdom (Section 15)
• Brazil (Section 16)
• China (Section 17)

If you have any questions or wish to exercise your rights and choices, please contact us as set out in Section 11.

For personal data transferred from the European Union, China, the UK, and Switzerland to third countries that do not ensure an adequate level of data protection, we will provide appropriate safeguards, such as through the use of Standard Contractual Clauses and related supplementary measures.

2. INFORMATION MAXMIND COLLECTS

Information You Provide

We collect information that you voluntarily provide to us while using the Services, such as when you register an account, make a purchase of one of our products or services, respond to our customer surveys, submit a data correction request, communicate with our customer service team, or apply for a job.
The information we collect includes information relating to identified or identifiable natural persons. The categories of information we collect include the following: contact data, including your first and last name, telephone number, email address, and postal address; billing information; credentials, including your passwords; content data, including the content of the messages you send to us; IP addresses or IP ranges you submit; and resume data, including data necessary to consider you for a job opening (such as your employment history, writing samples, and references). We also use payment processes to collect and process payment data, including your payment instrument and security code associated with your payment instrument, on our behalf.

You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.

Information Collected Automatically

We automatically collect information about your device and how your device interacts with our Services. The categories of information we automatically collect, and the methods by which we may collect such information include the following: Cookies, Web Beacons, and Embedded Scripts

The Services use "cookies" and similar technologies, including HTML5 local storage. A cookie is a file stored on your device that may be used to identify an individual as a unique user by storing certain personal preferences and user data. MaxMind uses cookies and other technologies to identify your device, identify authorized users of the MaxMind Account Portal, track affiliate referrals, complete online purchases through MaxMind's shopping carts, and similar Services monitoring activities.

MaxMind may also use web beacons, small graphic images or other web programming code (also known as "1x1 GIFs" or "clear GIFs"), which may be included in our web pages and e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

MaxMind may also use embedded scripts in connection with the provision of its Services. "Embedded scripts" are programming code designed to collect information about your interactions with a website, such as the links you click on, and may assist our customers in providing us with information used to provide the Services. The code is temporarily downloaded onto your device from our web server, our customer's web server, or a service provider or other party, is active only while you are connected to the website containing the embedded script and is deactivated or deleted thereafter.

Log File Information

Your web browser automatically sends information to every website you visit, including ours. For example, our server logs may receive and record information such as the pages you access on the Services, referring URLs, your browser type, your operating system, the date and time of your visit, and the duration of your visit to each page.

User Agent Strings

Log file information may also include a user agent string, a series of characters automatically sent with your Internet requests that provide information necessary for smooth Internet communications, such as the operating system and browser you used. A user agent string might be used to identify the device originating a message.

Non-Precise Location Data

MaxMind may also request access to or otherwise receive information about your device location when you access the Services. Your location data may be based on your IP address, which is non-precise. For clarity, MaxMind does not request access to or otherwise receive GPS signals from any devices when you access the Services. We use location data in connection with providing the Services and to help improve the Services.

Unique Identification Number

MaxMind may assign your computer or mobile device a unique identification number ("Unique ID") based on log file information when you access the Services. MaxMind may set a cookie on your device containing, amongst other things, the device's Unique ID. MaxMind uses information generated from the Unique ID for purposes of improving our Services, primarily our ability to detect fraud. MaxMind does not share the Unique ID or any associated data with unaffiliated parties in the traditional sense of sharing. However, some of the services offered by MaxMind, including some that are available through the Services, may require the placement of a snippet of JavaScript on the customer's own website (either by the customer itself or by MaxMind), and that JavaScript collects the information used by MaxMind to create the Unique ID. If the customer uses the MaxMind minFraud service, it may receive back the Unique ID MaxMind associated with the IP address being used in the request made to the minFraud service.

Information Collected through the GeoIP2 JavaScript Client API

MaxMind offers a GeoIP2 JavaScript Client API available to its customers via geoip-js.com and js.maxmind.com. Where a MaxMind customer uses the GeoIP2 JavaScript Client API, MaxMind collects IP addresses and other information (e.g., HTTP headers) provided via geoip-js.com or js.maxmind.com on behalf of the customer and logs such information only for the purposes of monitoring, alerting, and internal reporting for the specific customer for up to 30 days. MaxMind does not disclose information collected through geoip-js.com or js.maxmind.com among customers.

Information MaxMind Receives from Other Sources

MaxMind receives information about you from other sources. We may combine the information we receive from third parties with information we collect through the Services. If we do so, MaxMind will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. The categories of other sources from which we receive information include: our business partners and resellers; our customers; and publicly available sources such as open government databases or other data in the public domain. For example, our customers provide us with certain e-commerce transaction information, including IP address, cardholder name, billing and shipping address, email, and phone number.

3. HOW MAXMIND USES INFORMATION

We collect and use information for our legitimate interests and for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include the following: Providing Our Services

As stated above, MaxMind uses information such as your first and last name, telephone number, email address, postal address, billing information, or other contact information we obtain from you, our customers, or our business partners, for the purposes of providing, enhancing, or improving our IP geolocation, fraud detection, demographic targeting, databases, and other services and products.

Communications with You

MaxMind maintains one or more contact lists (with email addresses and other information) to allow MaxMind to communicate with individuals who do business with MaxMind or who have expressed an interest in the Services. We may contact you to confirm your purchases or respond to requests that you make, notify you of changes to your account or the Services, for marketing purposes, or to otherwise inform you of information related to our business or your account with us.

Website Administration and Customization

MaxMind uses the information we collect about you for a variety of website administration and customization purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customize features and marketing, deliver the Services content to you, measure Services traffic, measure user interests and traffic patterns, and improve the Services.

Usage of IP Addresses

The MaxMind services, including the minFraud service, use IP addresses to help organizations detect and prevent fraudulent activity. Among other things, MaxMind obtains IP addresses and order information (including customer name and billing address) through its minFraud service. MaxMind uses the billing location from this data along with other data to create databases that pair IP addresses with the locations in which they are likely being used, down to a postal code level of resolution.

Correction Requests

If you receive IP geolocation data from us that you believe is incorrect, you can submit a data correction request to us through our website at https://www.maxmind.com/en/geoip-data-correction-request, by email at [email protected], or through a secure URL that is set up by your company and that shares IP geolocation data. We use the information you submit to review and respond to your correction request and update our databases as appropriate. Any data updated within our databases may be used and disclosed in accordance with the practices described in this Privacy Policy.

Database Demos

If you use any of our database demos available at https://www.maxmind.com/en/geoip-demo, https://www.maxmind.com/en/locate-my-ip-address, and other parts of our website, we may use the information you submit to provide you with results and update our databases as appropriate. Any data updated within our databases may be used and disclosed in accordance with the practices described in this Privacy Policy.

Consent

We also use information with your consent, including to allow you to participate in our surveys, and to fulfill any other purpose disclosed to you and with your consent.

Some of our lawful bases for processing your information stem from our customers on whose behalf we provide services.
MaxMind uses information that does not identify you for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see Section 6 below.

4. HOW MAXMIND DISCLOSES INFORMATION

We disclose information we collect in accordance with the practices described in this Privacy Policy. The categories of sources to whom we disclose information include the following:

Service Providers

We provide your information to our service providers, and contractors for the purpose of delivering services to you as well as for purposes related to Services administration and operation, including conducting analytics and helping us with sales tax compliance. When disclosing information for the purpose of providing you with the services you request, we will disclose your information only as necessary for the service provider working on MaxMind's behalf to complete its work for us. For example, if you use a credit or debit card to complete a transaction on the Services, we will disclose your credit or debit card number with a payment processing and/or a fulfillment company in order to complete your transaction.

Databases

One aspect of MaxMind's products and services is the provision of databases to our customers and other third parties, including our business partners and resellers. These databases include information such as IP addresses and corresponding data pertaining to such IP addresses, such as non-precise geolocation data, fraud analysis data, and related information. Such databases are compiled using numerous data sources, including information we receive from our customers when individuals make purchases or conduct other transactions with our customers. In addition, we respond to API queries from our customers, and such responses may include information about the level of risk we associate with information about your device or email address, or your Unique ID.

Customers

We disclose your information to our customers in connection with us processing your information on their behalf. For example, we may disclose your information to our customers to provide them with our products and services, respond to your questions and comments, fulfill your requests, and otherwise comply with applicable law.

Vendors and Other Parties

We may disclose your information to vendors and other parties for the purpose of providing you with marketing, measuring, and improving our Service, and advertising effectiveness, and enabling other enhancements. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information.

MaxMind integrates with the service Have I Been Owned to verify whether your account password has previously appeared in a third-party data breach, which may allow MaxMind to evaluate the strength of the password, provide a warning, and/or block the password outright. We are not responsible for the effectiveness or accuracy of their information. For more information on Have I Been Owned, please visit the website at https://haveibeenpwned.com.

Security and Compliance with the Law

We reserve the right to disclose your information to appropriate third parties if we are required to do so by law or we believe that such action is necessary in order (a) to comply with a legal process such as a search warrant, subpoena, or court order; (b) to protect the company's rights and property; (c) to investigate reports of users sending material using a false email address or users sending harassing, threatening, or abusive messages; (d) to protect against misuse or unauthorized use of the Website or Services; or (e) to respond to emergencies, such as when we believe someone's physical safety is at risk. MaxMind may be required to disclose information in a life-threatening emergency or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Transfer of Business

Over time, MaxMind may buy or sell various assets. If we sell some or all our assets, or our company is acquired by another company, or during the negotiation of such sale or acquisition, our databases and any information we collect may be among the transferred or negotiated assets.
Consent

We may disclose your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, MaxMind discloses information that does not identify you to third parties, including our customers, for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we disclose your information, please see Section 6 below.

5. ANALYTICS AND ONLINE TRACKING

MaxMind works with certain other parties (including analytics companies) to provide us with information regarding traffic on and use of the Services. Some of these parties collect information when you visit the Services or other online websites and services. These other parties set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your IP address or other unique identifier, log information, and related information about you. These tracking technologies, including the Google Analytics User ID feature, may be used to assist in providing analytics, marketing, and for other purposes. We also use Google services to provide you with in-site search functionality. Both we and Google may collect, receive, and use your information because of your use of the Google services. MaxMind uses Google services operating under restricted data processing as described at https://business.safety.google/rdp. Google’s data practices are set out in its privacy policy available at https://policies.google.com/privacy. Some other parties may collect information about your online activities over time and across different websites when you use the Services.

6. YOUR RIGHTS AND CHOICES

Jurisdictional Rights

In addition to the rights and choices below, you may have additional rights based on your jurisdiction. Please visit the relevant “Additional Disclosures” section below for details.

Opt-Out of Email Communications

If you are a registered member of the Services, you can update your account information (including emails) by logging into the Website and modifying your preferences. In addition, certain email communications we send to you, such as newsletters and promotional announcements, contain a clearly worded "Opt-Out" or "Unsubscribe" link allowing you to withdraw your permission for future mailings. You may also opt-out of email marketing communications by contacting us at [email protected] with your request. Please note that we reserve the right to send you certain communications relating to your account or use of the Services (for example, administrative and service announcements) and these transactional account messages may be unaffected even if you opt-out from marketing communications.

Opt-Out from Database Disclosures

As discussed above in Section 4 of this Privacy Policy, MaxMind may disclose information we have about you in our databases to our customers and third parties as part of their use of the GeoIP Services. These services are used by our customers and third parties for security, fraud detection, to customize content for website visitors (including displaying the appropriate language, currency, streaming options, or to block visitors from sanctioned countries or regions), and other similar purposes. Some databases may be used for marketing and advertising purposes, for example to serve advertisements in a geographic area. MaxMind’s services are not intended to be used for the purpose of locating or identifying a specific individual or household. If you wish for your IP address not to be disclosed in services that may be used for marketing and advertising purposes, you may submit an opt-out by clicking on the Do Not Sell or Share My Personal Information and submitting your request. Please note that your ability to opt-out may be limited under certain circumstances, including where the opt-out adversely affects the rights and freedoms of other natural persons.

Blocking or Deleting Cookies

You can manually delete cookies, which are normally located in your temporary Internet folder or cookie folder. You can also reset the preferences in your web browser to notify you when you have received a cookie or, alternatively, to refuse to accept cookies. Deleting or blocking cookies will prohibit your ability to make online purchases on the Services and to use and access portions of the Services that require logging in with a username and password, and may affect other functionality.

Analytics and Do Not Track

You may exercise choice regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Your browser or extension may allow you to automatically transmit Do Not Track and other tracking technology preference signals, and unless required by law, we do not respond to such signals. If you are a California resident, please visit the “Additional Disclosures for California Residents” section below for details on how to exercise your right to opt-out of sales or sharing through preference signals.

7. INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. If your data is collected in the European Union, the UK, Switzerland, or in China, we will transfer your personal data subject to appropriate or suitable safeguards, such as through the use of Standard Contractual Clauses. Please visit the relevant "Additional Disclosures" section below for details."

8. SECURITY

MaxMind implements reasonable administrative, physical, and technical security measures to help protect your data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. MaxMind cannot guarantee the security of the Services' servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

9. POLICY REGARDING CHILDREN

The Services are not intended for use by children. MaxMind does not knowingly collect information from children under the age of thirteen. If you are a parent or guardian, and believe we have collected information about your child in violation of this policy, please contact us at the address set forth in Section 11 below. We do not knowingly "sell" as defined by the CCPA the personal information of minors under 16 years old who are California residents.

10. CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy in response to changing business circumstances and legal developments. If there are material changes to this Privacy Policy or in how we use your information, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this Privacy Policy to be informed of how we are collecting and using your information.

11. CONTACT FOR ADDITIONAL INFORMATION, OPTING OUT, DATA ACCESS AND CORRECTION, AND DISPUTES

If you have any questions or complaints about this Privacy Policy, or you wish to exercise your opt-out rights hereunder or access or correct data applicable to you, please contact us:

• By email: [email protected]
• By mail:

Privacy Agent
Legal Department MaxMind, Inc.
51 Pleasant Street #1020
Malden, MA 02148
U.S.A.

For residents of the EU and UK, Brazil-specific requests, and China-specific requests our Data Protection Officer may be reached at:
By email: [email protected]
By mail:
Data Protection Officer
MaxMind, Inc.
51 Pleasant Street #1020
Malden, MA 02148
U.S.A.
General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), MaxMind has appointed European Data Protection Office (EDPO) as its GDPR

Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

• by using EDPO's online request form: https://edpo.com/gdpr-data-request/
• by writing to EDPO at Block 1, Blanchardstown Corporate Park, Ballycoolin Rd, Dublin D15 AKK1

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, MaxMind has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

• by using EDPO's online request form: https://edpo.com/uk-gdpr-data-request/
• by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

12. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act as replaced by the California Privacy Rights Act ("CCPA") provides additional rights to California residents. This section addresses those rights and applies only to California residents.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

• Identifiers, including name, address, email address, account name, IP address – and an ID number assigned to your account.
• Customer records, phone number, billing address, and credit or debit card information.
• Commercial information, including purchases and engagement with the Services.
• Internet activity, including history of visiting and interacting with our Services, browser type, browser language and other information collected automatically.
• Non-precise Geolocation data, including location derived from an IP address.
• Employment and education data, including information you provide when you apply for a job with us.
• Inferences drawn.

For more information on the personal information we collect, including the sources we receive personal information from, review the "Information MaxMind Collects" section above.

We collect and use these categories of personal information for the business and commercial purposes described in the "How MaxMind Uses Information" section above.

We disclose personal information to the categories of persons set out in the “How MaxMind Discloses Information” section above.
Some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under CCPA to include a disclosure for cross-context behavioral advertising. MaxMind discloses the following categories of personal information for commercial purposes: identifiers, commercial information, internet activity, non-precise geolocation data and inferences. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors, business partners and customers. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.

Retention

We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

Right to Know, Correct, and Delete

You have the right to know certain information about our data practices. You have the right to request the following from us:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information was collected.
• The categories of personal information about you we disclosed for a business purpose or sold or shared.
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold or shared.
• The business or commercial purpose for collecting or selling or sharing the personal information; and
• The specific pieces of personal information we have collected about you.

In addition, subject to exceptions, you have the right to correct or delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our online form available at Right to Know: /en/ccpa/right-to-know, Correction Request: https://www.maxmind.com/en/geoip-data-correction-request, and Right to Delete: /en/ccpa/right-to-delete, call our toll free number at 1-844-802-0220, or email us at [email protected]. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

Right to Opt-Out

To the extent MaxMind sells or shares your personal information as those terms are defined under the CCPA, you have the right to opt-out of the sale or sharing of your personal information, which you can exercise (i) by clicking Do Not Sell or Share My Personal Information or (ii) by turning on a recognized opt-out preference signal, such as Global Privacy Control (“GPC”) in your browser or extension. If MaxMind detects a GPC signal in your browser or extension MaxMind will treat that as a request to opt-out of the sale or sharing of any personal information collected from your browser, but MaxMind will not opt your IP address out of our services unless you submit the webform located at Do Not Sell or Share My Personal Information.

To the extent "sale" under the CCPA is interpreted to include the disclosure of MaxMind’s databases as set out in the "How MaxMind Discloses Information" section MaxMind will comply with applicable law as to such activity. Please note that where we use and disclose personal information for purposes related to security, fraud detection, and other similar purposes, some of your rights may be limited to the extent that they adversely affect the rights and freedoms of other natural persons.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

Shine the Light

California's "Shine the Light" law permits customers who are California residents to request certain details about how a business shares their personal information as defined by "Shine the Light" with third parties (and in some cases affiliates) for those third parties' or affiliates' own direct marketing purposes. California customers may request information about our compliance with this law by contacting us by e-mail at [email protected] or by mail at the address set forth in Section 11 above. Any such inquiry must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email or mail address.

13. ADDITIONAL DISCLOSURES FOR NEVADA RESIDENTS

Nevada law requires certain businesses to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer from whom MaxMind has collected personal information and you wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected]. You may also submit a request to opt-out by clicking Do Not Sell My Personal Information.

14. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN VIRGINIA

The Virginia Consumer Data Protection Act (“VCDPA”) provides additional rights to Virginia residents. This section addresses those rights and applies only to Virginia residents.

You have the following rights under the VCDPA:

• To confirm whether we are processing your personal data.
• To access your personal data.
• To correct inaccuracies in your personal data.
• To delete your personal data.
• To obtain a copy of your personal data that you previously provided to us in a portable and readily usable format.
• To opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 45 days. If you have an account with us, we may require you to use the account to submit the request. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

If we refuse to act on a request, you may appeal our decision within a reasonable period time by contacting us at [email protected] and specifying you wish to appeal. Within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at https://www.oag.state.va.us/consumercomplaintform.

15. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE AND THE UNITED KINGDOM

Roles

EU and UK data protection laws make a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").

MaxMind, located at the address set forth in Section 11 above, generally operates as a processor on behalf of its customers that use the MaxMind's services. The MaxMind customer, the controller, determines the purposes and means of the processing of personal data. Specifically, MaxMind's customer decides what personal data to share with MaxMind in order for MaxMind to provide the customer with robust risk score information, certain licensed data, the ability to flag potentially fraudulent activity, and other services as purchased by the customer. Please visit the applicable customer's privacy policy for information about their privacy practices.

MaxMind also operates as a controller with respect to certain of its services and/or databases. For example, MaxMind operates as a controller in connection with personal data collected from visitors through its website, including through data correction requests. Also, when MaxMind combines personal data from different customers, like many kinds of analytics services, it may do this both as a processor at its customers' instruction and as a controller itself for the purpose of providing services to all its customers. For example, MaxMind may process and aggregate or otherwise de-identify some of the personal data that a customer shares with MaxMind to make that personal data part of another database for one or more other services provided to MaxMind customers.

Data Subject Rights

If you are a data subject in the European Union or UK, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us using the information at Section 11 above and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If your information has been processed by us on behalf of one of our customers and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to MaxMind, please provide the name of the MaxMind customer on whose behalf MaxMind processes your information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

International Transfer

For personal data transferred from the European Union, the UK, and Switzerland to third countries that do not ensure an adequate level of data protection, we will provide appropriate safeguards, such as using Standard Contractual Clauses.

In addition, MaxMind participates in the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from the European Union, the United Kingdom and Switzerland to the United States, respectively. MaxMind has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. In light of the judgment of the Court of Justice of the European Union invalidating Privacy Shield, MaxMind does not rely on Privacy Shield, but it will continue to process personal data in accordance with at least the standards of the Privacy Shield Principles.

MaxMind is subject to the investigatory and enforcement jurisdiction of the United States Federal Trade Commission where MaxMind has transferred personal data in reliance on Privacy Shield. We hereby affirm our commitment to comply with the Privacy Shield Principles for all personal data transferred from the European Union, the United Kingdom and Switzerland in reliance on Privacy Shield. This means that MaxMind shall be liable to you for any third-party agent to which we transfer your personal data in reliance on Privacy Shield and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages. MaxMind takes reasonable steps to ensure that personal data is relevant to its intended use and is accurate, complete, and current and retained only as long as needed for an intended or compatible purpose.

Any inquiries or complaints relating to MaxMind's compliance with Privacy Shield, including any requests for access or correction of personal data, may be addressed to our Data Protection Officer set forth in Section 11 of this Privacy Policy. MaxMind will investigate and attempt to resolve any inquiries brought to its attention. MaxMind has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you. Under limited circumstances, in the event your complaint is not resolved through these channels a binding arbitration option may be available for a Privacy Shield Panel.

Where MaxMind has transferred personal data in reliance on Privacy Shield, if there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

16. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN BRAZIL

Roles

Brazilian data protection laws make a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").

MaxMind, located at the address set forth in Section 11 above, generally operates as a processor on behalf of its customers that use MaxMind’s services. The MaxMind customer, the controller, determines the purposes and means of the processing of personal data. Specifically, MaxMind's customer decides what personal data to share with MaxMind for MaxMind to provide the customer with robust risk score information, certain licensed data, the ability to flag potentially fraudulent activity, and other services as purchased by the customer. Please visit the applicable customer's privacy policy for information about their privacy practices.

MaxMind also operates as a controller with respect to certain of its services and/or databases. For example, MaxMind operates as a controller in connection with personal data collected from visitors through its website, including through data correction requests. Also, when MaxMind combines personal data from different customers, like many kinds of analytics services, it may do this both as a processor at its customers' instruction and as a controller itself for the purpose of providing services to all its customers. For example, MaxMind may process and aggregate or otherwise de-identify some of the personal data that a customer shares with MaxMind in order to make that personal data part of another database for one or more other services provided to MaxMind customers.

Data Subject Rights

If you are a data subject in Brazil, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) when the processing is based on a lawful basis provided under the law. This kind of request is different from raising a concern that your consent is noncompliant with the provisions of the LGPD, including raising a concern that your data is being used for purposes materially different than for which it was originally collected. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us using the information at Section 11 above and specify which right you intend to exercise. To exercise your right for confirmation of the existence of processing, access to data, portability of data, deletion of personal data, revocation of consent, or information on public and private entities with which the controller has shared the data, please submit a request through our online form available at /en/lgpd. We will respond to your request within 30 days and within 15 days if you would like MaxMind to confirm if your data is processed by us or to exercise the right of access to your personal data. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If your information has been processed by us on behalf of one of our customers and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to MaxMind, please provide the name of the MaxMind customer on whose behalf MaxMind processes your information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

If you have any issues with our compliance, you have the right to lodge a complaint with the Brazilian supervisory authority or other authority indicated within applicable Law.

17. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN CHINA

Roles

Chinese data protection laws make a distinction between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors").
MaxMind, located at the address set forth in Section 11 above, generally operates as a processor on behalf of its customers that use MaxMind’s services. The MaxMind customer, the controller, determines the purposes and means of the processing of personal data. Specifically, MaxMind's customer decides what personal data to share with MaxMind for MaxMind to provide the customer with robust risk score information, certain licensed data, the ability to flag potentially fraudulent activity, and other services as purchased by the customer. Please visit the applicable customer's privacy policy for information about their privacy practices.

MaxMind also operates as a controller with respect to certain of its services and/or databases. For example, MaxMind operates as a controller in connection with personal data collected from visitors through its website, including through data correction requests. Also, when MaxMind combines personal data from different customers, like many kinds of analytics services, it may do this both as a processor at its customers' instruction and as a controller itself for the purpose of providing services to all of its customers. For example, MaxMind may process and aggregate or otherwise de-identify some of the personal data that a customer shares with MaxMind in order to make that personal data part of another database for one or more other services provided to MaxMind customers.

Data Subject Rights

If you are a data subject in China, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) when the processing based on one lawful basis provided under the law different from consent is carried out not in compliance with the Law noncompliance with the provisions of the Personal Information Protection Law ("PIPL") and other applicable laws, including for purposes materially different than for which it was originally collected. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us using the information in Section 11 above and specify which right you intend to exercise. To exercise your right for confirmation of the existence of processing, access to data, portability of data, deletion of personal data, revocation of consent, or information on public and private entities with which the controller has shared the data, please submit a request through our online form available at /en/pipl. We will respond to your request within 30 days if you would like MaxMind to confirm if your data is processed by us, or within 15 days if you would like to exercise the right of access to your personal data. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements, or if it is technically infeasible to delete such information.

If your information has been processed by us on behalf of one of our customers and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to MaxMind, please provide the name of the MaxMind customer on whose behalf MaxMind processes your information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.

If you have any issues with our compliance, you have the right to lodge a complaint with the Chinese supervisory authority or other authority indicated within applicable Law.

International Transfer

For personal data transferred from China to third countries that do not ensure an adequate level of data protection, we will provide appropriate safeguards, such as using Standard Contractual Clauses.
In addition, MaxMind will comply with rules under applicable law regarding the collection, use, and retention of personal data from China.
Any inquiries or complaints relating to MaxMind's compliance with applicable laws, including any requests for access or correction of personal data, may be addressed to our Data Protection Officer set forth in Section 11 of this Privacy Policy. MaxMind will investigate and attempt to resolve any inquiries brought to its attention.