Last Updated: November 2024
Anemoy and its affiliated entities (collectively, “Anemoy,” “we,” “our,” or “us”) are committed to protecting your privacy in accordance with all applicable data protection laws. References in this privacy policy to “Anemoy,” “we,” “our” and “us” are references to the entity responsible for the processing your personal data. This entity is also referred to as the data controller. Anemoy is a worldwide company headquartered in Ireland.
This Anemoy Privacy Policy (“Privacy Policy”) describes the types of information, including personal data, that Anemoy collects from you or that you may provide when you use our products and services (referred to collectively herein as the “Services”), as well as what we may collect from you as you otherwise interact with us or request Services from us as described further in this Privacy Policy. Services include, but are not limited to, our content on the websites located at https://www.anemoy.io/ and or any other webpages or mobile applications we own, operate or distribute (collectively, the “Website”).
This Privacy Policy also explains how Anemoy and its affiliated entities collect, use, maintain, protect, and disclose your personal data.Please read this Privacy Policy carefully. By using the Website, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, please do not use the Website or provide any personal data.
Residents of the European Union/European Economic Area and California have additional rights: See “ADDITIONAL REGION-SPECIFIC DISCLOSURES” attached to this Privacy Policy for additional disclosures, including certain rights, regarding any personal data that we process subject to relevant and applicable data protection legislation.
1. What personal data we collect
2. Why we collect your personal data
3. How we disclose your personal data
4. How we protect your personal data
5. How long we keep your personal data
6. Your rights with regard to your personal data
7. Third-party websites
8. Children’s privacy
9. How to contact us
10. Revisions to the privacy policy
11. Additional information for EU/EEA residents
12. Additional information for California residents
13. Additional information for residents of certain U.S. states
We collect and maintain several types of personal data about visitors to the Website, including both those who view only publicly-available content (“Visitors”) and end users (“Users”) of the Website or our Services. Personal data does not include anonymous data (i.e., information that cannot be associated with or tracked back to a specific consumer, household or device).
a. Personal Data You Provide We collect personal data that you provide to us directly through the Website and our Services. The personal data we collect from you includes:
- Device Information: We also automatically collect system information when you access or use the Website, such as device ID, IP address, device type, operating system type and version, browser, and browser language.
- Internet or Other Electronic Network Activity: Usage statistics about your interactions with our Website, including browsing history, search history, pages visited, time spent on pages, features used, your search queries, click data, date and time, your interactions with advertisements, and other data regarding your use of the Services.
- Geolocation Information: Country, city, and zip or postal code.
b. Data We Collect Automatically As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Device Information. We automatically collect system information when you access or use the Website, such as device ID, IP address, device type, operating system type and version, browser, and browser language.
- Internet or Other Electronic Network Activity. Usage statistics about your interactions with our Website, including browsing history, search history, pages visited, time spent on pages, features used, your search queries, click data, date and time, referrals from other websites and other data regarding your use of the Services.
c. Cookies and Other Automated Technologies The Website uses cookies, analytics tools, and other similar technologies to collect information about your equipment, browsing actions, and patterns to help the Website function effectively, improve our Services, and assist us with our marketing. For more information, please click here.
- Cookies: We may collect some information from you using a “cookie.” “Cookies” are small bits of data cached or stored on your computer based on Internet activity. They can be placed on your computer both by us and by third parties with whom we have a relationship, such as web analytic services and advertising network services. Cookies help us track and understand how individuals use and interact with the Website and otherwise manage the Website. We use single-session (temporary) cookies. Temporary cookies last only as long as your web browser is open and are used for technical purposes such as enabling better navigation on the Website. Once you close your browser, the cookie disappears. For more information on your choices regarding the use of cookies, please contact us using the contact information provided below under “How to Contact Us.”
- Website Analytics: We may use third-party web analytics services on the Website such as Google Analytics (the “Analytics Providers”). Analytics Providers help us analyze how Visitors and Users use the Website. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by Analytics Providers. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/. You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available here. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website. For more information about Google Analytics’ terms of use and Google’s privacy policy, please visit https://marketingSites.google.com/about/analytics/terms/gb/ and https://policies.google.com/?hl=en.
Anemoy may use personal data we collect from you for a variety of reasons, including for the following purposes:
- Fulfill our contractual obligations to you or your requests for Services or support.
- Operate the Website, its functions, and contents.
- Communicate with you about our Services and other Services that you may request from us or that we may provide.
- Answer contact requests from you or provide technical support to you.
- Notify you periodically about changes to the Website or any Services we offer.
- Market our Website and Services to you.
- Measure usage of the Website and analyze User or Visitor behavior, analyze the effectiveness of marketing and communications, and optimize the Website’s performance and our Services.
- Maintain, manage, and improve the Website and our Services.
- Help maintain the safety, security and integrity of the Website and our Services.
- Investigate and respond to suspected illegal activities or fraud.
- Enforce this Privacy Policy and any other terms that you have agreed to, including to protect the rights, property, or safety of us or any other person, or the copyright-protected content of the Website.
- Comply with applicable federal, state, local, and other laws and regulations and respond to law enforcement requests or other valid legal requests and as required by applicable law, court order or governmental regulations.
- Assess or effectuate a sale or purchase of businesses or assets or to assess or effectuate a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event. This includes to transfer your information to a success entity either after such a transaction or as part of due diligence processes while such a transaction is being contemplated.
- For any other purpose with your consent or authorization (where legally required).
Anemoy will only grant access to personal data on a need-to-know basis, and such access will be authorized and limited to the personal data that is necessary to perform the function for which such access is granted. Anemoy discloses the personal data we collect from and about you to the following categories of third parties:
- Affiliates and Agents. We may share your personal data within the Website, to our affiliates, parent companies, agents, employees, contractors, consultants, and other agents who require such information to assist us with establishing, maintaining, and managing our business relationship with you.
- Service Providers. We may share your personal data with third-party service providers that perform services on our behalf, including business, professional or technical support functions for us and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
- Business and Marketing Partners. We may share your personal data with business and/or marketing partners that research, develop, or improve products and services; conduct marketing; with whom we have commercial arrangements, partnerships or joint ventures; or otherwise with whom we have contractual relationships.
- Social Media or External Websites. Our Website contains links to independent social media websites or other websites, which are hosted by third parties and governed by their privacy policies, to enable you to share information with others and to allow us to better understand your interests and preferences.
- Government or Law Enforcement. We may use your information, including your personal data, to comply with any court order, law, or legal process, including to respond to any government, law enforcement, or regulatory request. We also may use your information if we believe disclosure is necessary or appropriate to protect and defend our rights, interests, property, or assets.
- Successors. We may disclose your personal data to a potential or actual buyer or other successor in the event of a merger, sale, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Anemoy about the Website’s Visitors and Users is among the assets transferred.
- Any Other Parties With Your Consent or Authorization. To anyone for whom you have authorized disclosure of information in this Privacy Policy.
Anemoy also may share anonymous non-personal data about Users with third parties for their marketing or analytics uses, without restrictions.
We put in place appropriate technical, physical, and organizational or administrative measures to protect personal data from accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, or misuse, taking into account the costs of implementation and risk. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, while we will strive to protect your personal data, we cannot and do not guarantee or warrant the absolute security of any of your personal data. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. We will not be and are not liable for disclosures of your personal data due to errors in transmission, networks that we do not control, nor unauthorized acts of third parties.
The Website may be hosted on, or integrated with systems hosted on, third-party vendors’ servers. We cannot control where these servers are located. You understand and agree that your information may be processed or stored wherever such servers may be, including the United States. For further information regarding how our vendors collect, use, and disclose your information, please refer to their terms of use and privacy policies, available on their respective websites.
The security of your personal data is important to us. Please advise Anemoy immediately of any incident where you suspect the loss of or unauthorized access to, or disclosure of your personal data that is in our custody or control.
In the event that we are required by law to inform you of any unauthorized access to your personal data, we may notify you electronically or in writing in accordance with applicable law.
We retain your personal data to fulfill the purposes for which it is collected, or as required by applicable laws and regulations. When determining the retention period, we take into account various criteria, including the length of time we have an ongoing relationship with you and provide the Services to you; the legitimate business purposes for which we collect and process your personal data as described in this Privacy Policy, and whether there is a legal obligation to which we are subject that requires us to keep records before we can delete them.
We have created the following mechanisms to provide you with control over your personal data:
- Cookies. The means by which you can refuse cookies through your web browser controls vary from browser-to-browser, so you should visit your browser’s help menu for more information. Please note that if you disable functional cookies on your browser, some parts of the Website may not work fully.
Depending on your local law, you may have certain rights regarding personal data we have collected about you. For more information on rights in certain jurisdictions, please see the section for the appropriate jurisdiction at the end of this Privacy Policy. There rights may include the right to:
- Access: The right to know what personal data we have collected about you and what personal data about you was disclosed to third parties.
- Correction/Rectification: The right to update or correct personal data if you believe there is an inaccuracy.
- Restriction: The right to restrict the processing of your personal data under certain circumstances, such as where you contest the accuracy of your personal data, processing is unlawful, your personal data is no longer needed for the purposes of processing, or you have otherwise objected to processing related to automated individual decision-making.
- Deletion/Cancellation: The right to request deletion of your personal data. Please note that the deletion of your personal data may prevent us from providing you content or other benefits that depend on the processing of your personal data.
- Objection/Opposition: The right to object to our use of your personal data.
- Data Portability: The right to request transmission of your personal data to another data controller.
- Withdraw consent: The right to withdraw consent you previously provided to us regarding the processing of your personal data at any time. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your withdrawal of consent.
Certain of these rights may be subject to limitations or conditions. You may also be able to limit the use and disclosure of your personal data in order for them not to be processed by following the procedure mentioned below.
If you would like to exercise any of these rights provided under local law, you may contact us using the information provided below in Section 9. We will not discriminate against you for exercising any of these privacy rights. We may charge you a fee to access your personal data; however, we will advise you of any fee in advance.
If you would like to make a complaint about how we handled your personal data, or make a complaint about a potential violation of data protection laws, please contact us using the information provided below in Section 9. Complaints will be investigated and the outcome of the investigation will be communicated to you after the complaint is made in accordance with applicable law. You may have a right in some locations to file a complaint with your local data protection authority.
The Website and email messages from us may contain links to third-party websites, which may have privacy policies that differ from our own. You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy. Anemoy therefore encourages you to read the privacy policies and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. ANEMOY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL DATA. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.
We do not knowingly collect personal data from children under the age of 16. If you are under 16, please do not give us any personal data. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data to Anemoy without their permission. If you have reason to believe that a child under the age of 16 has provided personal data to us, please contact us using the contact information provided below under “How to Contact Us,” and we will endeavor to delete that information from our databases.
We hope this Privacy Policy answers your questions about our collection, use and disclosure of your personal data. If you have additional questions about this Privacy Policy or the practices described herein or would like to make a complaint, you may contact us at:
Email: legal@anemoy.io
Postal Address: Unit 4 First Floor, 84 Strand Street Skerries, CO. Dublin K34VW93 Ireland
Attention: Privacy Policy
Anemoy reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will revise the “Last Updated” date at the top of the privacy policy. You should revisit this page periodically to become aware of the most recent privacy terms. Your use of the Website after such changes have been posted constitutes your agreement to such changes.
Under applicable law and regulations, you may, at any time, exercise certain rights, as described below.
If you live in the European Union (“the EU”) or European Economic Area (the “EEA”), the following additional disclosures apply to your personal data that we process subject to relevant and applicable data protection legislation.
Lawful Bases of Processing
The lawful bases on which we rely to process your personal data are:
- You have provided us with your consent to do so. You can withdraw your consent at any time by contacting us via the contact details set forth in this Privacy Policy above.
- Processing is necessary for the performance of a contract to which you are a party.
- Processing is necessary for us to comply with a legal obligation to which we are subject.
- We have a legitimate interest in processing your personal data.
International Data Transfers
We may transfer, use and/or store your personal data outside the EU/EEA, including to or in the United States and other countries that do not offer the same protections for personal data. Your personal data may also be processed by personnel who work for us or for a third-party service provider but who operates outside the EU/EEA.
Transfers to third-party service providers are to enable them to use and store your personal data on our behalf. We have, however, put in place appropriate security procedures to protect your personal data. Where your data is transferred to any country outside the EU/EEA, we use safeguards and in compliance with applicable laws, including EU Standard Contractual Clauses.
We shall notify you of any data breach that is reasonably likely to result in a risk to the interests, fundamental rights, or freedoms of either you or those data subjects to whom the relevant data relates.
Data Subject Rights
You have the following data subject rights, though the extent of these rights may vary by EU member state:
- Request access to your personal data.
- Request correction of inaccurate or incomplete personal data that we hold about you.
- Request deletion of your personal data.
- Request restriction of the processing of your personal data.
- Withdraw your consent at any time to the processing of your personal data (such as direct marketing) that is based on your consent.
- Object to or request that we cease the processing of your personal data.
- Request to transfer your personal data to another party in a machine-readable, commonly used and structured format.
- Complain to the relevant supervisory authority.
Your rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to object to processing, we may continue processing your personal data if needed to fulfil a legal or contractual requirement. If you want to exercise any of your rights, please contact us using the contact details set forth in this Privacy Policy above.
How to Contact Us or Make a Complaint
If you wish to request further information about any of your rights, or if you are not satisfied with how we have handled your data, please contact us using the contact details set forth in this Privacy Policy above.
If your complaint is not satisfied by our response or if you believe our processing of your data does not comply with applicable data protection laws, you can make a complaint to the relevant supervisory authority in your country.
A. Disclosures of Your Personal Information for a Business Purpose
We collect the following categories of personal information (also known as personal data) from California residents for the following business purposes and disclose personal information to the following categories of third parties:
Identifiers
IP addresses, unique device identifiers, device type, operating system type and version, browser, and browser language
Directly from you when you use the Website.
Servicing and improvement of the Website and Services
Maintain records
Legal compliance
Affiliated companies and subsidiaries
Business partners Marketing or analytics service providers
Professional or technical support service providers
Government or law enforcement
Internet or Other Electronic Network Activity Information.
Collected automatically based on a consumer’s interaction with the Website or Services.
Servicing and improvement of the Website and Services
Maintain records
Legal compliance
Affiliated companies and subsidiaries
Business partners Marketing or analytics service providers
Professional or technical support service providers
Government or law enforcement
Geolocation Data
Country, city, and zip code.
Directly from you when you use our Website.
Provide Services
Improve Services
Marketing and analytics
Affiliated companies and subsidiaries
Business partners Marketing or analytics service providers
Professional or technical support service providers
Government or law enforcement
We collect the following categories of personal information (also known as personal data) from California residents for the following business purposes and disclose personal information to the following categories of third parties:
C. Your California Privacy Rights
If you are a California resident, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (Civil Code Section 1798.100, et seq.) (collectively “California law”), may provide you with specific rights regarding your personal data. This California Privacy Rights section supplements the Privacy Policy and applies solely to eligible residents of California as of January 1, 2023. Any terms not defined in this section have the same meaning as defined in California law. These rights may include:
- Information about Collection, Use, Sale, Sharing or Disclosure: You have the right to be informed of the categories of personal data that we collect about you, the purposes for which the categories of personal data are collected or used and whether we sell or share such personal data. You also have the right to be informed of the length of time we intend to retain each category of personal data.
Notice of and Access to Your Personal Data: You have the right to request that we disclose the categories of personal data that we collect about you; the categories of sources from which your personal data is collected; the business or commercial purpose for collecting, selling or sharing your personal data; the categories of third parties to whom we disclose your personal data; and the specific pieces of personal data that we collected about you.
- Deletion Request Rights: You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will conduct a reasonable search of our records in order to locate any personal information we have collected from you that is eligible for deletion, and delete such personal information. We are not required to delete any personal information we have collected about you in certain circumstances described in applicable California laws.
- Correct Inaccurate Personal Data: You have the right to request that we correct any of your personal data that we maintain about you.
- Non-Discrimination or Retaliation: Unless permitted by applicable law, we will not retaliate or discriminate against you for exercising any of your privacy rights under California law or other applicable law, including by denying you goods or Services; charging you different prices or rates for goods or Services, including through the use of discounts or other benefits or imposing penalties; providing you a different level of quality of goods or Services; or suggesting that you will receive a different price or rate for goods or Services or a different level of quality of goods or Services.
- Your Rights under “Shine the Light”: California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information disclosed and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2023 will receive information about 2022 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request by emailing us at legal@anemoy.io and placing “Privacy Policy” in the subject line.
- Right to Appeal: You have the right to appeal any decision or indecision related to the exercise of any right you are granted under California Law.Non-affiliated third parties are independent from Anemoy and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.
D. How to Exercise Your California Privacy Rights
To exercise the California Law rights described above, please submit a verifiable consumer request to us by emailing us at legal@anemoy.io
To exercise your right to access, delete or correct your personal data as described above, we need to verify your identity or authority to make the request and confirm the personal data relates to you. To verify your identity, we may ask you to provide your full name, email address, telephone number, and address.
Only you or an authorized agent (“Authorized Agent”) may make a verifiable consumer request related to your personal data. When an Authorized Agent is submitting a request on your behalf, we require your Authorized Agent to provide evidence of their entitlement, which must include information sufficient to identify you and the purpose of the request, and at least one of the following:
- written and signed permission designating the Authorized Agent to act on your behalf. You must verify your identity with us and directly confirm with us that you have provided the Authorized Agent permission to submit the request;
- evidence that you have provided the Authorized Agent with power of attorney pursuant to the California Probate Code; or
- proof that the Authorized Agent is a person or business entity registered with the California Secretary of State and that you have authorized such person or business entity to act on your behalf.
Absent such documentation, we reserve the right to refuse to comply with third-party requests for information. You also may make a verifiable consumer request on behalf of your minor child.
For eligible residents of Colorado, Connecticut, Utah, Virginia, Oregon, Texas, and Montana, you also have rights with respect to the personal data, also known as personal information, that we collect about you. This section supplements this Privacy Policy and applies solely to eligible residents of Colorado, Connecticut, Utah and Virginia. Any terms not defined in this section have the same meaning as defined under applicable data protection laws in these states. Subject to certain exceptions, if you are an eligible resident of one of these states, you have certain privacy rights which may include, depending on your state of residency:
- Right to Access. You have the right to confirm whether we process your personal data and access such personal data. You also have the right to obtain your personal data in a portable, and to the extent reasonable feasible, readily usable format that you can transmit without hinderance.
- Right to Delete. You have the right to request that we delete the personal data you have provided to us or that we have otherwise obtained about you.
- Right to Correct. You have the right to request that we correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data.
- Right to Opt Out. You have the right to opt out of the processing of your personal data for the purposes of profiling in furtherance of decisions, including, solely automated decisions for eligible residents of Connecticut, that produce legal or similarly significant effects.
- Right to Appeal. You have the right to appeal decisions with regard to your request to exercise any rights described herein.
exercise the rights described in this section, including your opt-out rights, please submit a verifiable consumer request to us by emailing us at legal@anemoy.io
