Privacy Policy

Last Updated: September 1, 2020

This Privacy Policy describes the policies and procedures of Launchmetrics on the collection, use and disclosure of your information, and what choices you have with respect to the information.

When we refer to « Launchmetrics », « us » or « our », we mean Fashion GPS Inc. and its affiliates. In accordance with the applicable legislation on data protection, Launchmetrics is the Controller (or Business under the CCPA) of the Personal Data referred to in this Privacy Policy.

We receive information about you from various sources, including: (i) certain contact information and other information about yourself when you make an inquiry on the website, and (ii) your use of the website generally. When you make an inquiry or otherwise use the website, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

Our Privacy Policy applies to all visitors, users, and others who access our websites.

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personal data (“Personal Data”) gathered when you are using or accessing launchmetrics.com (the “Site”) and other interactions (e.g., customer services inquiries, newsletter, etc.).

This Privacy Policy also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

Our Privacy Policy applies to all of the services offered by Launchmetrics and its affiliates, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

What Information Do We Collect and Receive?

The information we gather enables us to personalize, improve and continue to operate the Site. In connection with certain aspects of the Site, we may request, collect and/or display some of your Personal Data. We collect the following types of information from our users:

Usage Information:

  • IP Address Information and Other Information Collected Automatically. We automatically receive and record information from your web browser when you interact with the Site, including your IP address and Cookie information. Generally, the Site automatically collects usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Site so that we can analyze and improve them.
  • Log Data. We do not have website “logs” as our Site is totally open. You will need to leave Personal Data only for downloading content or for request of information on our Site. A checkbox will be available on every online form you complete to make sure you consent to give us such Personal Data.
  • Device Identifiers. When you access the Site by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Site. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Site. Some features of the Site and Site may not function properly if use or availability of device identifiers is impaired or disabled.
  • Location Data. When you access the Site by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the Site and Site. Some features of the Site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
  • Aggregate Information. We collect statistical information about how, collectively, users use the Site (“Aggregate Information”). Some of this information is derived from Personal Data. This statistical information cannot be tied back to you or your web browser.

Cookies Information:

We use Cookies and similar technologies in our Sites and Services that help us collect other information. The Sites and Services may also include Cookies and similar tracking technologies of third parties, which may collect information about you via the Sites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookies Policy.

Contact Information:

If you submit an inquiry through the Site, we may collect Personal Data such as your first and last name, your current job and employer, your email address and telephone number and the country where you are currently located. Before you submit an inquiry containing contact information you will be asked to tick a checkbox so we are sure that you understand the reason why we may collect such information and you will also be provided with a link to this Privacy Policy.

In order to improve the type of content you receive through our subscription channels, we use in our contact & content forms a feature that is called ‘Progressive Profiling’. It is the tool we use for marketing automation and it records your visit through Session Cookies. Once your IP is identified, the type of information that we ask you through our forms may vary when you access or download content two or more times on our website. In this way, your profile in our CRM platform is progressively enriched and allows us to offer you a unique and personalized experience through our emails according to your profile and interests.

When you submit an inquiry, you will always be asked for permission before we send marketing communication (e.g. newsletters and Discover coverage newsletter, campaign emails, etc). If you DO NOT wish anymore to receive marketing communication from us, please send us an email:dataprotection@launchmetrics.com or directly unsubscribe from marketing communication by clicking on the unsubscribe link.

You are free to explore the Site without providing any Personal Data about yourself but some information may be collected automatically, and if some information, such as account details, is not provided, we may be unable to provide the Services.

To avoid features such as the ‘Progressive Profiling’ of our forms, you can always perform your browsing in incognito mode (more info here)  or deactivate your browser Cookies (Check our Cookies Policy here).

How Do We Use the Data Collected?

Your Personal Data will be used by Launchmetrics in accordance with your instructions, including any applicable terms in agreements and use of Services functionality, and as required by Applicable Laws. Your Personal Data include the data communicated by you when using the forms on the site.

Different Launchmetrics entities provide the Services in different parts of the world. Data protection laws in certain jurisdictions (in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), altogether “Applicable Laws”) differentiate between the “controller” and “processor” of information or Business and Service Provider.

Launchmetrics is the data controller of the data processing involving your Personal Data collected through our Site (a “Business” under the CCPA). The purpose of this data processing is to provide you with our Services and to facilitate your navigation on our website as explained below.

We use the Personal Data you provide to us to:

  • Enable us to provide you with the Services and information offered through the Site and which you request;
  • Analyse use of the Site and the people visiting in order to improve our content and services including research into our users’ demographics;
  • Facilitate your navigation of our Site;
  • Send you information we think you may find useful or which you have requested from us, including receipt of marketing communications, provided you have indicated that you want to be contacted for this purpose.
  • Track which emails are opened and which links you click (via web beacons).

Public Information about Your Activity on the Site:

Some of your activity on and through the Site may be public by default. This may include, but is not limited to, content you may post publicly on the Site.

Information concerning your use of the Site (such as what pages they have visited) may be tracked anonymously through the use of Cookies and stored by us.

Please also remember that if you choose to provide Personal Data using certain network features of the Site, then that information is governed by the privacy settings of those particular features and may be available to others. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Site.

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information Shared with Analytical Services:

We use certain analytics providers (including but not limited to Google Analytics, Inspectlet, Google Optimize, Hotjar) in order to better understand how the Site is used and how it can be improved. Your IP address information may be accessed by one or more of such analytics providers. In addition, information regarding the usage activity of a certain portion of users of the Site may be shared, but such information is shared on an anonymous basis and does not reveal the identity of any individual User. These providers do not collect any personal information or store IP address locally on their websites.

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use the Site and their services or websites, which facilitates improving both their services and how the Site interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce these Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and you will be able to prevent the sharing of this information.

Is Information About Me Secured?

We work hard to secure your Personal Data from unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Data we hold by taking appropriate Technical and Organisational Security Measures, having regard to the state of the technological development and the cost of implementing any measures where appropriate, for example, pseudonymisation and encryption of Personal Data.

Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within 72 hours of the becoming aware of it. This information can be provided in phases to facilitate a fast and efficient reporting.

Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly with the following information:

  • The nature of the Personal Data breach including, where possible:
  • The categories and approximate number of individuals concerned; and
  • The categories and approximate number of Personal Data records concerned.
  • The name and contact details of the Data Protection Officer or other contact point where more information can be obtained.
  • A description of the likely consequences of the Personal Data breach.
  • A description of the measures taken, or proposed to be taken, to deal with the Personal Data breach and, where appropriate, of the measures taken to mitigate any possible adverse effects.
  • The servers that store your Personal Data have appropriate administrative, technical, and physical controls that are designed to safeguard your Personal Data, including industry-standard encryption technology.

If you have any questions or concerns regarding security using the Site, please send us a detailed message to security@launchmetrics.com. We will make every effort to answer your concerns. Any security inquiries will be handled using our Launchmetrics Security Incident Practices documentation.

Notice for California residents

The content of this section is aimed solely at providing California residents with relevant information under the California Consumer Protection Act (CCPA), and only applies to Personal Information for which Launchmetrics is a Business (as defined in the CCPA). It must be construed in addition and not in lieu of the full Privacy Policy.

Information we may collect:

California law requires us to disclose certain information regarding the Personal Information we collect in the 12 months prior to the effective date of this Privacy Policy. We have collected Personal Information from you, your devices, our partners, third parties, and from categories of sources otherwise described above in this Privacy Policy.

Although we do not sell Personal Information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties (website analytics companies, providers of email services, and security vendors and event sponsors/partners) to receive certain combined Personal Information such as, identifiers and commercial information that are collected directly from you and Internet or other electronic network activity (e.g. cookies) collected from your usage of the Site.

We do not sell personal information in exchange for any monetary consideration. We share Personal Information as necessary for certain business purposes, as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and described in the section “How Do We Use the Data Collected? of this Privacy Policy. California residents may opt out of the sale of their Personal Information. While Launchmetrics does not sell Personal Information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. We wish to provide you with control over how your Personal Information is collected and shared. If you would like to opt out of Launchmetrics’ use of your Information for such purposes (when considered as a sale), you may do so by contacting us. With respect to cookies, you can customize your settings when you access the Site and change them at any time.

Your rights:

Under the CCPA, you have the following rights:

  • Right to Know and Access: You have the right to request that we disclose to you the (i) categories of Personal Information we collect, use, or share, (ii) purposes for which the Personal  Information is collected or used by us, (iii) categories of sources from which we collect the Personal  Information, and (iv) information about our data practices;
  • Right to Delete: You have the right to request that we delete the Personal  Information  we currently hold about you. If you ask us to delete some or all of your information that is needed to provide the Service to you, you may no longer be able to access or use the Services.
  • Right to Equal Service: We will not discriminate against you for exercising any of these rights.

Please note that these requests apply only to information that Launchmetrics holds as a Business. If your request relates to the Personal Information collected through a third party’s website or services, you should direct your request to the owner of that website or service.

If you have additional questions about this section or how to exercise your rights under the CCPA, please contact us at support@launchmetrics.com. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.

California’s Shine the Light Law:

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 115 E 23rd Street, Floor 6, New York, NY 10010, USA. The request should attest to the fact that you are a California resident, and provide a current California address.

Your rights under GDPR (for EEA residents)

Personal Data” means personal data as defined in the GDPR.

Process” or “Processing” means any operation or set of operations performed upon Personal Data, whether or not by automatic means, such as creation, collection, procuration, obtaining, accession, recording, organisation, storage, adaption or alteration, retrieval, consultation, dissemination or otherwise making available, use, disclosure by transmission, restriction, erasure or destruction.

Under the General Data Protection Regulation (GDPR), you have the right to ensure that:

  • we process your Data fairly and lawfully within the consent you have provided us.  
  • your Data is accurate.
  • your Data is secure.

You can:

  • ask confirmation of whether, and where, a Controller is processing Personal Data;
  • ask us to provide details of the Personal Data we hold on you (information about the purposes of the processing, the categories of Data being processed, the categories of recipients with whom the Data may be shared,and obtain a copy of the Personal Data being processed (see the contact information below);
  • know how long we keep your Personal Data;
  • use your rights to erasure, to rectification, to restriction of processing and to object to processing, or to complaint to relevant authorities;
  • obtain information regarding the source of the Data if the Data were not collected directly from you ; and
  • obtain information about the existence of, and an explanation of the logic involved in, any automated processing that has a significant effect on you or other data subjects.

We will maintain complete and accurate records and information to demonstrate our compliance with our obligations under this Privacy Policy and also for audits conducted by you or on your behalf.

To exercise any of these rights, please contact us at support@launchmetrics.com or dpo@launchmetrics.com, or by mail to Launchmetrics, 115 E 23rd Street, Floor 6, New York, NY 10010, USA, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

How Long Do We Conserve Your Data?

Launchmetrics will retain your Personal Data in accordance with your instructions, including any applicable terms in agreements and use of Services functionality, and as required by Applicable Laws and only for the period of time necessary to fulfill the specific purposes for which the Data were collected or further processed, if for compatible purposes.

What Happens When There are International Data Transfers?

We are a global organisation, as such, we may share information about you within Launchmetrics offices and with affiliates and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy.

In some cases, we use suppliers located in various countries to collect, use, analyse, and otherwise process information on its behalf. It is our practice to require such suppliers to handle information in a manner consistent with our policies and special rules under European and UK data protection law and in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection.

For transfers of Personal Data outside of the EEA, we are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the Applicable Laws.

Our standard practice is to use EU Standard Contractual Clauses that have been approved by the European Commission (also called Model Clauses), to meet the GDPR requirements for our customers who operate in the E.U.

How Do I Review or Change my Personal Data?

If you would like to review or change your Personal Data, we will deal promptly and appropriately with any inquiries unless we have to keep that information for legitimate business or legal purposes. However, if your requests are deemed to be excessive or complex a small fee may be charged and a time-period extension may apply.

You can contact us at: support@launchmetrics.com.

How Do I Opt-Out & Unsubscribe?

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information or delete, transfer, access, update any Personal Data that you have provided to us and used by the Site or our Services.

You can contact us at: support@launchmetrics.com.

How do you Protect Children’s Privacy?

Launchmetrics does not knowingly collect Personal Data from children under the age of thirteen (13). If you believe we might have any information from or about a child under thirteen (13), please contact us at: support@launchmetrics.com.

What Happens When There are International Data transfers?

Although most changes are likely to be minor, Launchmetrics will occasionally update this Privacy Policy to reflect company and customer feedbacks about the Site. Changes and clarifications will take effect immediately upon their posting on this Site. Launchmetrics encourages you to periodically review this Privacy Policy to be informed of how we are protecting your information and check for any changes. We have the sole discretion to modify this Privacy Policy. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services.

Do you have a Data Protection Officer?

Yes, if you would like to communicate with our Data Protection Officer, please send a message to dpo@launchmetrics.com.

How to contact us?

If you have any questions or concerns regarding privacy using the Site, please send us a detailed message to support@Launchmetrics.com. We will make every effort to resolve your concerns.

English Version Controls


Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

 


 

We have made revisions to this Privacy Policy, effective May 25th, 2018. By continuing to use our services after May 25th, you agree to the new Privacy Policy. A summary of changes can be found on our GDPR Resource Center Page here.