Owner and Data Controller

Greta Rose Agency HQ
2149 Cascade Ave.
Suite 106A-49
Hood River, OR 97031

Owner contact email: gps@gretarose.com

Types of Data collected

Among the types of Personal Data that gretarose.com collects, by itself or through third parties, there are: first name, last name, email address, Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geographic position and phone number.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using gretarose.com.
Unless specified otherwise, all Data requested by gretarose.com is mandatory and failure to provide this Data may make it impossible for gretarose.com to provide its services. In cases where gretarose.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by gretarose.com or by the owners of third-party services used by gretarose.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through gretarose.com and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner 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 the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of gretarose.com (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 the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

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

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. 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.

The Owner 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 to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Analytics, Advertising, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Location-based interactions, Displaying content from external platforms, Registration and authentication, Managing contacts and sending messages and Handling payments.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Advertising

  This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on gretarose.com, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside gretarose.com. For more information, please check the privacy policies of the relevant services.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.

  Gretarose.com may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Facebook Ads conversion tracking (Facebook, Inc.)

  Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on gretarose.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google Ads conversion tracking (Google Inc.)

  Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on gretarose.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of gretarose.com, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  LinkedIn conversion tracking (LinkedIn Corporation)

  LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on gretarose.com.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Contacting the User

  Contact form (gretarose.com)

  By filling in the contact form with their Data, the User authorizes gretarose.com to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data collected: email address, first name and last name.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of gretarose.com and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Instagram widget (Instagram, Inc.)

  Instagram is an image visualization service provided by Instagram, Inc. that allows gretarose.com to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy.

  Vimeo video (Vimeo, LLC)

  Vimeo is a video content visualization service provided by Vimeo, LLC that allows gretarose.com to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Wistia widget (Wistia, Inc.)

  Wistia is a video content visualization service provided by Wistia, Inc. that allows gretarose.com to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  YouTube video widget (Google Inc.)

  YouTube is a video content visualization service provided by Google Inc. that allows gretarose.com to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Handling payments

  Payment processing services enable gretarose.com to process payments by credit card, bank transfer or other means. To ensure greater security, gretarose.com shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  PayPal Carrier Payments (PayPal Inc.)

  PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile phone operator.

  Personal Data collected: phone number and various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  PayPal Payments Hub (PayPal Inc.)

  PayPal Payments Hub is a payment service provided by PayPal Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of gretarose.com.
  The interaction and information obtained through gretarose.com are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google+ +1 button and social widgets (Google Inc.)

  The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  PayPal button and widgets (PayPal Inc.)

  The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Pinterest “Pin it” button and social widgets (Pinterest)

  The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy.

• Location-based interactions

  Geolocation (gretarose.com)

  Gretarose.com may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by gretarose.com.

  Personal Data collected: geographic position.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  MailChimp (The Rocket Science Group, LLC.)

  MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

  Personal Data collected: email address, first name and last name.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Registration and authentication

  By registering or authenticating, Users allow gretarose.com to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, gretarose.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Log In with PayPal (PayPal Inc.)

  Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  MailChimp OAuth (The Rocket Science Group, LLC.)

  MailChimp OAuth is a registration and authentication service provided by The Rocket Science Group, LLC and is connected to the MailChimp service.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Pinterest OAuth (Pinterest)

  Pinterest OAuth is a registration and authentication service provided by Pinterest, Inc. and is connected to the Pinterest social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Remarketing and behavioral targeting

  This type of service allows gretarose.com and its partners to inform, optimize and serve advertising based on past use of gretarose.com by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of gretarose.com with the Facebook advertising network.

  Personal Data collected: Cookies and email address.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of gretarose.com with the Facebook advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their 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 their 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 their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• 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.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner 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.

Cookie Policy

GPSmember.com uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of gretarose.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, gpsmember.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, gretarose.com and any third-party services may collect files that record interaction with gretarose.com (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Gretarose.com does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within gretarose.com and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. 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, the Owner shall collect new consent from the User, where required.