1.      LEGAL INFORMATION

This Privacy Policy explains how Greetline handles information and personal data on their website https://greetline.com, referred to as the Platform.
This website provides information about our company, our business, our alliances and third party relationships, and our services.  We strive to protect all personal information that we receive or generate. This Privacy Policy (“Privacy Policy” or “Policy”) explains our data protection practices for our website visitors. This Privacy Policy also explains the nature of the personal information we collect, the means by which we collect it, the purposes for which we collect it, and how we use, process, protect, and share it.
This site is owned by Greetline and may be accessed in the United States and abroad. For data protection purposes, Greetline is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.
Please read this entire Privacy Policy before submitting information to this Platform. By accessing or using this Platform for any purpose and by submitting any of your personal information to us, you are consenting to the terms and conditions of this Policy and to our Terms of Use posted on this Platform.
If you disagree with any part of this Privacy Policy or the Terms of Use, please do not use this Platform or any of our other services and do not share any personal information with us.
This Policy includes supplemental terms that apply solely to California residents covered by the California Consumer Privacy Act (“CCPA”).
Data Controller: Greetline LLC, Address: 2810 N Church St, Wilmington, Delaware 19802.

Contact information: e-mail address: hello@Greetline.com

2.      DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data) – Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data – This Platform collects information automatically. It includes IP addresses, domain names, and URI addresses of the computers used by Users. It also includes the time of the request, method of submitting the request, file size received, server response code, country of origin, browser and operating system used by the User, and details about the time spent on each page and the sequence of pages visited. Other parameters related to the device’s operating system and the user’s platform may include: the IP addresses or domain names of the computers used by the users, the URI addresses, the time of the request, the method used to submit the request to the server, the size of the received file, the numerical code indicating the server’s response status, the user’s country of origin, the browser and operating system used by the user, the duration of each page visit, and the sequence of pages visited. These parameters provide details about the user’s IT environment.
User – The individual using this Platform who, unless otherwise specified, coincides with the Data Subject (includes influencers, musicians and any other person using the Platform).
Data Subject – The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor) – In this privacy policy, the term ‘Processor’ refers to any individual or organization, whether they are a natural person or a legal entity, who processes Personal Data on behalf of the Controller, such as a public authority, agency, or other body.
Data Controller (or Owner) – The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Platform. The Data Controller, unless otherwise specified, is the Owner of this Platform.
GDPR – GDPR is a regulation that protects people’s personal data and allows the free movement of this data within the European Union. It was enacted by the European Parliament and the Council on April 27, 2016.
Profile – the User’s dedicated account and environment when he/she has registered on a Platform.
This Platform – The means by which the Personal Data of the User is collected and processed.
Service – The service provided by this Platform as described in the relative terms (if available) and on this Platform.

3.      COLLECTING OF DATA

3.1. Account Registration

3.2.Contact Us

3.3.Content on the Platform

3.4. Other Means of Collection.  We collect personal information by a variety of means and methods, including the following:

4.      COLLECTED DATA

We collect the following categories of Personal data for the following activities:

5.      PURPOSE OF DATA COLLECTION 

We use the personal information that we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, sharing with our affiliates for related business purposes, and as follows:
         To provide and maintain our Service, including to monitor the usage of our Service.
         To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
       For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
      To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication.
       To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
       To manage your requests: To attend and manage your requests to us.
       To respond to your requests and questions, resolve disputes, investigate and address your concerns, and monitor and improve our responses;
       To help maintain the safety, security, and integrity of our Platform, databases, and technology assets and to detect and prevent transactional fraud;
       For testing, research, analysis, and a product and service development, including to improve our Platform, products, and services;
       For facilitating and processing your transactions with us and with our third party affiliates and business partners;
       To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations;
       For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We process personal data on the following legal basis for the following purposes:

6.  METHODS OF DATA PROCESSING

Greetline takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Greetline, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Greetline. The updated list of these parties may be requested from the Owner at any time.

7.      TRANSFERS AND SHARING OF DATA

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own.  Your personal information is stored on servers in the European Union. Also, some of our service providers may store information on servers hosted in countries different from where you reside.
As such, your personal information may be subject to the laws of other countries, where the data protection and other laws may not be as comprehensive as your country of residence.

If there is a transfer, users should check specific sections of this document or contact Greetline for more information. For instance, with processors, partners, or businesses Greetline enters into data processing agreements and/or Standard Contractual Clauses (where necessary and as published by the European Union) to safeguard the processing of your Personal data.
In doing so, Greetline also commits these recipients to ensure the protection of your Personal data when it is further transferred (e.g. to one of their sub-processors). However, please note that for activities carried out outside the Platform (e.g. if you are redirected on a third-party platform or application), Greetline will no longer act as Data controller. Therefore, you must refer to such third-party’s data protection policy to know more about their commitments and your rights.
We may share your personal data with the following recipients:
Internal recipients – Your personal data will only be shared with authorized employees who need it to fulfill their obligations, such as support teams and developers. require authorization to fulfill their obligations (e.g. support teams, developers, etc.).
       Our trained employees understand the importance of protecting your personal data and respecting your right to privacy.
       Processors – in order to provide the Services, Greetline may communicate your Personal data to other entities acting as data processors.
       Partners and third parties – Greetline may share your personal data with third party service providers when providing the service. This applies when you buy a subscription and use payment methods from other companies like Stripe, or when you use our hosting platform, Wix.com.
       Other Users – Sharing personal data on the platform allows other users to access your profile and any personal data you share such as messages, comments, and posts.
Greetline shares personal data with public authorities if legally required or upon request from a competent authority. This may be done to follow a court order, seek legal help, protect Greetline’s rights, or assist in investigations like fraud or identity theft. 

8.  RETENTION TIME 

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

1.   Personal data collected for a contract between the owner and the user will be kept until the contract is completed.
   
2.   Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes.
   
3.   Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

Greetline may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

9.  RIGHTS UNDER GDPR

Users may exercise certain rights regarding their Data processed by Greetline. In particular, users have the right to do the following:
       Withdraw consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
       Object to processing of Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
       Access Data. Users have the right to know if their Data is being processed by the Owner. They can also request information about certain aspects of the processing and obtain a copy of the Data being processed.
       Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
      Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
       Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
       Receive their data and have it transferred to another controller.  Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
       Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Any requests to exercise User rights can be directed to Greetline through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
If users encounter any issues regarding data processing done by Greetline users can send requests to competent national data protection authority. 

10.  PRIVACY POLICY SUPPLEMENT FOR CALIFORNIA USERS

This Privacy Policy Supplement for California Users (“Supplement”) adds additional terms to those contained in this Policy that apply solely to residents of the State of California who are subject to the California Consumer Privacy Act of 2018, as amended (“CCPA”).

Any terms defined in the CCPA that are not otherwise defined in this Supplement shall have the same meanings as such terms are given in the CCPA.

The CCPA provides Users with certain additional rights and information regarding their personal information.  This Supplement provides those disclosures and describes those additional rights and explains how such additional rights may be exercised.  Please read this Supplement as an expansion of the terms of the Policy set forth above as to Users interacting or doing business with us.
Categories of Personal Information Collected.
Listed below are the categories of personal information that we collect and use in our business for commercial purposes.  These categories of data do not all apply at all times or as to all Users and often our receipt of this data is based on a User’s voluntary submission of it to us for specific purposes or transactions requested by the User:

Category
Examples
A. Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
B. Commercial information
regarding subscriptions to Services of the Platform.
C. Internet or other network activity
Online browsing history, search history or other information relating to a User’s interaction with the Platform.

Sale of Personal Information
The CCPA requires that we disclose if we sell the personal information of Consumers to third parties which do not meet the definition of Service Providers under the CCPA.  The common understanding of the term “sell” is to transfer property (in this case, personal information) for monetary consideration (i.e. cash), but under the CCPA, the definition of “sell” includes exchanging data for a business benefit other than cash. We do not share or sell customers’ personal information with any third parties that are not considered Service Providers under the CCPA.

California Residents’ Rights

We extend the following rights to Users relating to their personal information that we have collected, used, or hold (collectively,“ Data Rights”):
When Data Rights Do Not Apply.  Data Rights are subject to certain exceptions and limitations based on the specific data processing activities involved or other legal constraints like law enforcement and litigation uses.  If any of these exceptions or limitations should apply to a Data Rights request, we will explain in our response why (or the extent to which) we are unable to honor a User request.

Data Rights Described. Users have certain rights regarding their personal information. These rights apply to a Data Rights Request if and when applicable. (a “Data Rights Request”).

The Right to Know.  A User has a right to request that we disclose certain information to him or her about our collection and use of the User’s personal information over the past 12 months.  Upon such a request, after verification of the User’s identity, we will confirm (i) the categories of personal information we have collected about the User, (ii) the categories of sources from which such information was collected, (iii) the business or commercial purpose for our collection, disclosure or use of such data, (iv) the categories of any third parties with which we shared such personal information for a business purpose, and (v) the specific pieces of personal information we have collected about the User.
The Right of Deletion.  In some circumstances, a User has the right to request that we delete personal information that we have collected from or about the User. There are situations when we don’t need personal information anymore, when the user no longer agrees to the processing based on their consent, or when our data processing goes against the policy or is illegal. There are exceptions to the right of deletion.
Situations where we need to keep and process data include: (A) Completing transactions, fulfilling warranties or product recalls, or carrying out contracts with the user. (B) Providing requested products or services, or taking actions within the context of our ongoing relationship with the user. (C) Detecting security incidents or protecting against deceptive, fraudulent, or unlawful activity. (D) Using data for internal purposes that align with the user’s expectations or applicable laws. (E) Complying with legal obligations.
The Right to Data Portability  In certain circumstances under the Right to Know, a User has the right to access the specific pieces of his or her personal information that we collected from such a User, by mail or electronically, and if provided electronically, in a portable, readily usable format to the extent technically feasible.
This right does not apply when there are other legal needs that outweigh it or when returning the information would harm the rights or interests of others, for example, if the information cannot be separated from other protected data.
Right to Opt-Out of the Sale of Personal Information  If and to the extent we are deemed to Sell a User’s personal information to a third party, the User has the right to direct us to stop Selling the User’s personal information to such third parties (the (“Right to Opt-Out”).  To exercise the Right to Opt-Out, the User may submit a Data Rights Request Form to us invoking such right.  The Consumer does not need to create an account with us to exercise his or her Right to Opt-Out.  We will only use personal information provided in an opt-out request to review and comply with the requesting User’s request.  A User’s exercise of the Right to Opt-Out will only apply to our disclosures to third parties which are not Service Providers and will not affect our own communications and transactions with our User or communications by our business partners with our Users in connection with our own business activities.

Any Data Rights Request must:

Please provide enough information so we can verify that the requester is the individual we collected personal information from or their authorized representative. We cannot respond to a request or provide personal information. If we cannot verify the requestor’s identity or authority to make the request and confirm that the personal information relates to them.

       Such verification requirements include proof of the identity of the User about whom a request is made either (i) by a third party identity verification service engaged by us, or (ii) by our matching the identifying information of the User at issue with the personal information of the User already maintained by us, either in a password-protected account with the User or by identification of the User’s recent vehicle searches or other activities with us or our business partners.

       Describe the Data Rights Request with sufficient detail for us to properly understand, evaluate and respond to it.

Users do not need to create an account with us to submit a Data Rights Request, but we do consider requests made through a password-protected account sufficiently verified when the request relates to personal information associated with that account.  We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

We will promptly confirm receipt of any such request (generally within ten to 10 days) and endeavor to substantively respond to it after verification within forty-five (45) days of its receipt.  If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically or as otherwise agreed.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  We do not charge a fee to process or respond to verifiable Data Rights Requests unless excessive, repetitive, or manifestly unfounded.

Authorized Agent: The CCPA allows California consumers to designate an authorized agent to exercise their rights under the CCPA. 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 your rights.

 11.  ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Legal action
The User’s Personal Data may be used for legal purposes by Greetline in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related Services.
System logs and maintenance
This Platform and third-party services may collect files that record interactions with the Platform (System logs) and use other Personal Data (like the IP Address) for operation and maintenance purposes. 
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Greetline at any time. Please see the contact information at the beginning of this document.

Children
The site is intended for a general audience and is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at. We will remove the data to the extent required by applicable laws.
We do not knowingly “sell” the personal information of minors under 16 years’ old who are California residents without their affirmative authorization.
If you are a resident of California and under 18 years old, you can request us to remove any content or information that you have posted on our site. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Visiting Third-Party Platforms 
Our Platform may contain links or references to third party Platforms. These Platforms are outside our control, and the privacy policies of these sites may differ from our own. Please be aware that we have no control over these third-party Platforms and our Privacy Notice does not apply to such platforms. We encourage you to check the terms of use and privacy policies of such sites before disclosing any personal information via such sites. The privacy notice of the third party site will govern how information collected from you is used by the owner of the Platform. You can always know what Platform you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser.

12.  CHANGES TO THIS PRIVACY POLICY

Greetline reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Platform and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to Greetline. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, Greetline shall collect new consent from the User, where required.
Latest update: September __, 2023

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