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Privacy Policy

Last updated: March 14, 2022

Our approach to privacy

  1. Abstract is a version control software platform that allows you to upload, manage and grant other users permission to view and edit digital design documents, images and related materials (the "Abstract Service").
  2. The Abstract Service is provided to you by Abstract Studio Design, Inc. ("Abstract", "we", "our", or "us"). We are committed to protecting your privacy. This privacy policy explains our practices regarding the collection, use, disclosure, and protection of information.
  3. The Abstract Service is available in many different countries, which may have different standards and requirements in respect of the information we provide in this privacy policy and how we use personal information.
  4. This privacy policy is therefore made up of two parts: Part 1 sets out information applicable to users outside the European Economic Area or Switzerland, and Part 2 sets out information applicable to users in the European Economic Area or Switzerland.
  5. Before you access or use the Abstract Service, please ensure that you have read this privacy policy and understood how we collect, store and disclose your personal information as described in the part of this privacy policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our privacy policy explains how we collect, use, disclose and protect information that is collected through the Abstract Service from users outside the European Economic Area or Switzerland, as well as your choices regarding the collection and use of information.

  1. What Information do We Collect and for What Purpose?

    We collect personal information when you voluntarily submit information directly to us when you use the Service. We also collect personal information from you indirectly such as information about how you use the Service and the device you use to access the Service.

    The categories of information we collect can include:

    • Contact information and other information you provide to us directly.  We may collect personal information, such as your name, email address, username, and password when you register for our Service, sign up for our mailing list, or otherwise communicate with us.  We may also collect any communications between you and Abstract and any other information you provide to Abstract. We will use your contact details to create an account for you so that you can use the Service, to communicate with you directly about the Service and about any queries, issues or concerns you or other users have and to send you marketing communications in accordance with your preferences. 
    • Payment information. We will ask you to provide your payment information if you purchase any products or services on the Service, such as your credit or debit card number, cardholder name, expiry date and CVC number. We will use these details to process payment for the relevant services, to monitor and improve our site and our procedures and to help us develop new products and services. We will not store this information, but will provide it to Recurly, a third-party subscription service provider. Please refer to their website for more information about how they store your payment information (https://recurly.com/).
    • Data collected through your use of the Service. We collect information about how you use the Service, your actions on the Service, and content you post to the Service, including text, and other files you post to the Service, and content you provide through any other functionality (“User Content”). Please remember that Abstract may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Service, you consent to the recording, storage, and use of such communications you send or receive for these purposes.
    • Information we receive from third parties. Other users, such as your employer or anyone else that wishes to grant you access to the Service (the “Customer“), may provide personal information about you to us, such as through private messages or when granting you access to a Customer Account. We will use this information in order to provide you with the appropriate level of access to materials and pages on the Service, to respond to queries, issues or concerns the Customer or other user raises, to assist other users who want to invite users to the Service or who want to share information about the Service. This information will also be made available to other users of the Abstract Service, to enable the Customer to manage your activity on the Service in accordance with the Terms of Service: https://www.abstract.com/legal/customer-terms-of-service/ . We may also collect information about you that is publicly available.
    • Information collected automatically about how you use the Service. We and our third party service providers may collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. In some instances, we and our third party service providers may combine this usage information with other personal information. For more information on Cookies, how we use them and how you can control them, please see our Cookie Policy https://www.abstract.com/legal/cookie-policy/ . Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
    • Comments and opinions. When you contact us directly, e.g. by email, phone, post or by completing an online form, we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys, entering competitions or taking part in promotions we run. We will use your comments and opinions to address your queries, issues and concerns and improve our products and services. We will also use comments and opinions you express when responding to surveys, entering competitions or taking part in other promotions to determine products and services that may be of interest to you and to send you marketing communications in accordance with your marketing preferences.
    • Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location. We may use an approximate location to ensure content on the Service is relevant to the city, state or country you are using your device in, to monitor and improve the Service and our procedures and processes, and to help us develop new products and features.

    We will use all the personal information we collect to monitor and improve the Service and our business, including for the purposes of detecting and preventing fraud or crime. We also use the personal information we collect to help us develop new products and services. We may anonymize and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service and developing new products and features

  2. Sharing of Your Information

    We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.

    We may share your personal information with: 

    • Other users of the Service and any Customer that grants you access to the Service. Your information may be shared other users of the Service, as needed to provide the Services to you. For example, some of your information may be shared with your employer and with other employees of the same employer to facilitate the Service. You may be able to control the visibility of some of your information and actions through your Settings (see “Your Choices Regarding Your Information” below). We also share information about your use of the Service with your employer for analytic purposes. For example, we may provide reporting to allow an employer to evaluate the efficiency of its workforce, and its employees’ responsiveness and availability;
    • Third parties at your request. For example, you may have the option to share your activities on the Service with your friends through email, text, or on various social media sites;
    • Other companies and brands owned or controlled by Abstract and other companies owned by or under common ownership as Abstract, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy;
    • Third-party vendors, advisors and other service providers that perform services on our behalf, as needed to carry out their work for us. For example, we may use third parties to provide certain features of the Service, to help support our IT infrastructure, to develop analytical information for us about our services, and to provide professional services such as legal and accountancy services. We will only share personal information with these third parties as needed to perform the requisite Service on our behalf. These third parties will only be allowed to use your personal information to assist us and will be required to keep your information secure;
    • The public when you provide feedback on our Service. For example, if you post User Content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our Service or on our social media pages;
    • Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
    • Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service: https://www.abstract.com/legal/customer-terms-of-service/ or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Abstract, our visitors, or others.

    We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

  3. Customer Information

    In providing our Service, our Customers may upload data to our Service, which may include personal information or data about our customers’ end users (all of which we call “Customer Data”). Customer Data is owned and controlled by our Customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our Customers, and in accordance with our agreements with the Customers. We do not use or disclose Customer Data except as authorized and required by our Customers and as provided for in our agreements with our Customers. Our obligations with respect Customer Data are defined in our agreements with our Customers. Each Customer will remain responsible for the privacy and security of the Customer Data that it collects and processes and for compliance with applicable data protection laws that may apply to the collection, processing and disclosure of Customer Data through the Service.

  4. Control Over Your Information

    Profile and Data Sharing Settings. You may update your profile information, such as your user name and contact information and may change some of your data sharing preferences on your Settings page within the application (app.abstract.com).

    How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

    Modifying or deleting your information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at Legal@abstract.com.We may not be able to modify or delete your information in all circumstances.  Please note that Abstract does not own or control the Customer Data uploaded to our Service by our Customers and cannot modify or delete Customer Data except at the request of our Customer, or as permitted by our agreement with Customer.

  5. Third-party Tracking and Online Advertising

    We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Service over time so that they may play or display ads on our Service, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.   

    To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again.  

    You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).

    Google Analytics and Advertising.  We use Google Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, log in to your account on our Service, or otherwise engage with us.  We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service.  Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/.  You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

    We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

  6. How We Store and Protect Your Information

    Data storage and transfer:  Your information collected through our website may be stored and processed in the United States or any other country in which Abstract or its affiliates or service providers maintain facilities.  If you are located in other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. If you are located in the European Union, please see our EU Privacy Policy https://www.abstract.com/legal/privacy-policy/ and DPA https://www.abstract.com/legal/data-processing-addendum/ . Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy.

    Keeping your information safe: We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

  7. Children’s Privacy

    Abstract does not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at Legal@abstract.com.

  8. Links to Other Web Sites and Services

    The Service may contain links to and from third-party websites of our business partners, advertisers, and social media sites and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

  9. How to Contact Us

    If you have any questions about this Privacy Policy or the Service, please contact us at legal@abstract.com.‍

  10. Changes to our Privacy Policy

    We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the ‘last modified’ date at the top of this page. If you object to any changes, you may close your account. Continuing to use our Service after we publish changes to this Privacy Policy means that you are consenting to the changes.

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area or Switzerland.

  1. Who is Responsible for the use of your Personal Information

    1. There are various ways in which we collect and receive personal information about you when you use the Abstract Service, and our relationship with you with respect to your personal information will vary depending on our relationship with you, how we collect this personal information and how we use it.
    2. In certain circumstances we will act as the controller of your personal information, which means we determine and are responsible for how that information is used.
    3. In other circumstances we act as a processor on behalf of another person, meaning that our use of this personal information is governed by our Terms of Service https://www.abstract.com/legal/customer-terms-of-service/ and, where applicable, the data processing addendum https://www.abstract.com/legal/data-processing-addendum/ .
    4. The following summarises where we believe we act as a controller and where we would consider ourselves to act as a processor:
      1. When you subscribe to the Abstract Service and set up an account, whether on your own behalf or on behalf of your employer, we will be the controller of your personal information that you provide to us, such as your name and other contact details, your payment details and transaction details (including the details of the type of service you have purchased).
      2. When someone else sets up an account on the Abstract Service (the "Customer") and gives you access to the Abstract Service (and makes you an "Authorised User"), such as your employer or someone you are working with on a project on the Abstract Service, we will process the personal information about you (such as your contact details) that they submit to us as a processor on their behalf.
      3. When you use the Abstract Service, we will be a controller in respect of any information about your use of the Abstract Service, such as the pages you access and functionalities you use, as well as information about the type of device you use to access the Abstract Service.
      4. When you submit support requests to us, we will process any personal information contained in that support request as a processor on behalf of the relevant Customer.
      5. When you submit comments and opinions to us, and we use those comments and opinions to improve the Abstract Service or develop new products, we will be the controller of the personal information contained in those comments and opinions; and
      6. When you upload digital documents, images and related materials uploaded to the Abstract Service, we will process personal information contained in any such materials uploaded to the Abstract Service as a processor on behalf of the relevant Customer.
    5. This privacy policy applies to our use of your personal information when we act as a controller of that personal information

  2. Personal Information We Collect About You and How We Use It

    1. The table at Annex 1 sets out the categories of personal information that we collect about you when you subscribe to the Abstract Service and when you correspond with us and submit comments and opinions to us. It also sets out the purposes for which we will process this personal information and the lawful basis we rely on to do so, as well as the recipients of that personal information.
    2. We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Abstract Service. If you choose not to provide such personal information, we may not be able to provide those parts of the Abstract Service to you or respond to your other requests.
    3. We also collect personal information about you automatically when you use the Abstract Service. The table at Annex 2 sets out the categories of personal information that we collect about you in this way. It also sets out the purposes for which we will process this personal information and the lawful basis we rely on to do so, as well as the recipients of that personal information.
    4. We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Abstract Service and developing new products and features.

  3. Information we share with Third Parties

    1. In addition to the recipients identified in Annex 1 and Annex 2, we may share your personal information with the following parties:
      1. Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our holding company or ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries they own. These companies will only use your personal information to provide a service to us or to you in the same way as we can under this privacy policy.

        ‍Service providers and advisors: third parties who provide a service to us. For example, we may use third parties to provide certain features of the Abstract Service, to help support our IT infrastructure, to develop analytical information for us about our services, and to provide professional services such as legal and accountancy services. These third parties will only be allowed to use your personal information to assist us and will be required to keep your information secure.
      2. Purchasers of our business: personal information may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of any such sale.
      3. Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or to whom we need to disclose your personal information to protect our rights, property or safety or to protect the rights, property or safety of others. We may also disclose personal information to third parties to help detect and investigate illegal activities and breaches of any agreement we have with you.
    2. We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of the Abstract Service but we will make sure no one can be identified from this information before we disclose it.

  4. How long we store your personal information

    1. We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

  5. Cookies and similar technologies

    1. Abstract uses technologies such as: cookies, web beacons, locally shared objects (sometimes called "flash cookies"), mobile identifiers and similar technologies ("Cookies"). We use Cookies to to distinguish you from other users of our website, to assist you with logging into our Services, and also to provide us with analytical data regarding users’ use of our Services and website; for more details, please see our Cookie Policy
    2. These technologies may be used in analyzing trends, administering the Abstract Service, tracking users’ movements around the Abstract Service and to gather information about our user base as a whole. You can control the use of Cookies at the individual browser level, but if you choose to disable Cookies, it may limit your use of certain features or functions on our website or service. For more information on Cookies, how we use them and how you can control them, please see our Cookie Policy located at https://www.abstract.com/legal/cookie-policy/.

  6. Tracking Technologies Used in our Emails

    1. Our emails may contain tracking technologies that provide us with information about your interactions with our emails, including identifying if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
    2. Most popular email clients will allow you to block these technologies by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.
    3. Some browsers also give you the option of downloading and installing extensions that block tracking technologies.

  7. Marketing and Advertising

    1. From time to time we may contact you with information about our products and services. For some marketing messages, we may use personal information we collect about you to help determine the most relevant marketing information to share with you.
    2. Most marketing messages will be in the form of emails to the email address you provide to us. We will only send you these marketing messages if you have given us your consent to do so. If you want to stop receiving marketing messages, you can change your marketing preferences by following the "unsubscribe" link at the bottom of each marketing email you receive from us.
    3. We may allow third parties to deliver certain advertising about products and services that they believe may be of interest to you based on information about how you use the Abstract Service and data associated with your device via mobile advertising platforms. We may share information about your use of the Abstract Service with third party advertising companies for this purpose.
    4. Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Abstract Service and information about which adverts you have seen or clicked on.
    5. You may be able to limit interest-based advertising through the settings on your mobile device or on some PCs by selecting “limit ad tracking” (iOS), “opt-out of interest based ads” (Android) or by disabling access to your advertising ID in the Privacy settings on Windows 10. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. Some social media websites, such as Facebook, also allow you to adjust your ad preferences, which might affect the advertising displayed to you. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
    6. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
    7. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
    8. Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.

  8. Storing and transferring your personal information

    1. Security: we implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage..
    2. International Transfers of your Personal Information: As we are located in the USA, any information you provide will initially be collected and stored in the USA. If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will always take reasonable steps to ensure that your personal information is treated securely and in accordance with this privacy policy and applicable law (including the rights you have under EU data protection law).
    3. Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield ("Privacy Shield"). To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/.
    4. Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our obligations in the Standard Contractual Clauses as set forth in the DPA. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.  In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  9. Your rights in respect of your personal information

    1. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
      1. Right of access. You have the right to obtain:
        1. confirmation of whether, and where, we are processing your personal information;
        2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
        3. information about the categories of recipients with whom we may share your personal information; and
        4. a copy of the personal information we hold about you.
      2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
      3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
      4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
      5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
    2. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason.
    3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
    4. You may also review and edit some of the personal information you have submitted to us through the appropriate functionality on the Abstract Service.
    5. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
    6. We will seek to respond to any request relating to your rights within one month of receipt of such request.
    7. Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the extended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an extension is required.
    8. Where we do not follow up on your request, we will inform you within the one month deadline of the grounds on which we have based our decision and of you right to refer a complaint to your national data protection authority.

  10. Jurisdiction and Enforcement

    1. As part of our participation in the EU-US and Swiss-US Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).
    2. If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

  11. Contact ABSTRACT and recourse

    1. In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at legal@abstract.com.
    2. In the event that you are concerned about how personal information you have provided to Abstract has been used, please address your inquiry or complaint first to us at the address listed above. Abstract takes all concerns about privacy and use of personal information very seriously, and shall endeavor to reply to you within 45 days of receiving a complaint.
    3. We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS, Inc. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. This service is provided free of charge to you.
    4. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.

  12. Links to third party sites

    The Abstract Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

  13. Our policy towards children

    The Abstract Service is not directed at persons under 13 and we do not knowingly collect personal information from children under 13. If you become aware that a person under 13 has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to delete this information.

  14. Changes to this policy

    We may update this privacy policy from time to time and so you should review this policy periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

  15. Notice to you

    If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Abstract Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

  16. Contacting us

    Questions, comments and requests regarding this privacy policy are welcome and should be addressed to legal@abstract.com.‍

ANNEX 1 – PERSONAL INFORMATION YOU PROVIDE TO US
Category of personal information
How we may use it
Legal basis for the processing
Recipients of personal information
Vistor ID
We may use this information to set up and authenticate your account
If you are the Customer, the processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.
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If you subscribe to the Abstract Service on behalf of a Customer, the processing is necessary for the Customer's legitimate interests, namely setting up and administering the Customer's account.
We may use this information to set up and authenticate your account
The processing is necessary for our legitimate interests, namely administering the Abstract Service, and for communicating with you effectively to respond to your queries or complaints.
We may use this information to communicate with you, including sending service-related communications
If you are the Customer, the processing is necessary for the performance of a contract with you.
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If you subscribe to the Abstract Service on behalf of a Customer, the processing is necessary for our legitimate interests, namely providing service related information and updates.
We may use this information to send you unsolicited marketing communications in accordance with your preferences
We will only use your personal information in this way to the extent you have given us consent to do so.

We may share this information with:

  • our subscription management service provider, in order to enable us to charge you or the Customer, and manage your or the Customer's subscription to the Abstract Service;
  • our customer support platform provider, in order to communicate with you and deal with your requests;
  • our cloud hosting provider;
Payment and transaction information, such as your credit card, payment authentication code, billing address, and other information such as the groups and accounts you set up on the Abstract Service.
We may use this information to process the payments you make through the Abstract Service.
If you are the Customer, the processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.
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If you subscribe to the Abstract Service on behalf of a Customer, the processing is necessary for our legitimate interests, namely billing the Customer in respect of their use of the Abstract Service.
We may share this information with our subscription management service provider, in order to enable us to charge you or the Customer, and manage your or the Customer's subscription to the Abstract Service.
Chat, comments and opinions. When you contact us directly, e.g. by email or phone, we will record your comments and opinions.
We may use this information to address your questions, issues and concerns.
The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.
We may use this information to address your questions, issues and concerns.
The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We may share this information with:

  • our customer support platform provider, in order to communicate with you and deal with your requests;
  • our survey and feedback platform provider, in order to obtain feedback and comments from you about the Abstract Service.
Your preferences, such as preferences set for notifications, marketing communications, how the Abstract Service is displayed and the active functionalities on the Abstract Service.
We use this information to provide notifications, send news, alerts and marketing communications and provide the Abstract Service in accordance with your choices.
The processing is necessary for our legitimate interest, namely ensuring each user receives the correct marketing and other communications, and that the Abstract Service is displayed in accordance with users' preferences.
We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.
The processing is necessary for compliance with a legal obligation to which we are subject.

We may share this information with:

  • our subscription management service provider, in order to charge you or the Customer in accordance with your billing preferences;
  • our cloud hosting provider;
    our customer support platform provider, in order to receive and document your preferences.
  • our customer support platform provider, in order to optimize our customer support and messaging service.
All personal information set out above.
We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Abstract Service, to communicate with you, to monitor and improve the Abstract Service and business, and to help us develop new products and services.
The processing is necessary for our legitimate interests, namely to administer and improve the Abstract Service.
ANNEX 2 – PERSONAL INFORMATION WE COLLECT AUTOMATICALLY
Category of personal information
How we may use it
Legal basis for the processing
Recipients of personal information
Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.
We may use information you provide to us about your location to inform and plan our marketing strategy and to monitor and detect fraud or suspicious activity in relation to your or a Customer's account.
The processing is necessary for our legitimate interests, namely informing our direct marketing strategy and monitoring fraud.
We may use this information to tailor how the Abstract Service is displayed to you (such as the content that is provided to you through the Abstract Service and/or the language in which it is provided to you).
The processing is necessary for our legitimate interest, namely tailoring the Abstract Service so that it is more relevant to our users.
Information about how you access and use the Abstract Service. For example, how frequently you access the Abstract Service, the time you access the Abstract Service and how long you use it for, the approximate location that you access the Abstract Service from, whether you access the Abstract Service from multiple devices, and other actions you take on the Abstract Service.
We may use information about how you use and connect to the Abstract Service to present the Abstract Service to you on your device.
The processing is necessary for our legitimate interests, namely to tailor the Abstract Service to the user.
We may use this information to determine products and services that may be of interest to you for marketing purposes.
The processing is necessary for our legitimate interests, namely to inform our direct marketing.
We may use this information to monitor and improve the Abstract Service and business, resolve issues and to inform the development of new products and services.
The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Abstract Service and to improve the Abstract Service generally.
Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Abstract Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Abstract through the device, your mobile network, your IP address and your device’s telephone number (if it has one).
We may use information about how you use and connect to the Abstract Service to present the Abstract Service to you on your device.
The processing is necessary for our legitimate interests, namely to tailor the Abstract Service to the user.
We may use this information to determine products and services that may be of interest to you for marketing purposes.
The processing is necessary for our legitimate interests, namely to inform our direct marketing.
We may use this information to monitor and improve the Abstract Service and business, resolve issues and to inform the development of new products and services.
The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Abstract Service and to improve the Abstract Service generally.

We may share this information with:

  • our data analytics providers, in order to create aggregate statistics and data for our research and development;
  • our cloud hosting provider;
  • our data aggregation and integration services provider, in order to facilitate the interaction of our analytics platforms; and
  • our customer support platform provider, in order to optimize our customer support and messaging service.