Privacy Policy

GENERAL

Your privacy is important to us, and CAVE is committed to ensuring that your privacy is protected. This privacy policy is intended to give you confidence in the privacy and security of the personal information we obtain from you by visiting our websites.

Please read this Privacy Policy carefully. By using or accessing the Service (defined below), you acknowledge that you have read, understood, and agree to be bound to all the terms and conditions of this Privacy Policy, and the “Terms of Use” or other customer agreement between you and CAVE that is applicable to the particular Service you are using or accessing (collectively, “User Agreements”).

If you do not agree to this Privacy Policy and the applicable User Agreement, please exit, and do not access or use, the Service.

We try to use a simple language so that it is understandable, but if you’re not familiar with any terms in the text such as “cookies”, or “IP” feel free to contact us. Your privacy is really important to us, so whether you’re new to CAVE or a long-time user, please take the time to get to know our practices.

INTRODUCTION

This Privacy Policy (“Privacy Policy”) sets forth the privacy practices of CAVE Private Company and its current and future CAVE Affiliates (collectively, “CAVE”) for all CAVE software and applications (including, without limitation, mobile software and applications) (collectively, the “Software”); the CAVE websites located at www.cave.edu.gr, www.thecaveapproach.com and any other CAVE websites or services that link to this Privacy Policy, (collectively, the “Websites”); and all other CAVE products or services provided or otherwise made accessible on or through the Software or the Websites or that otherwise link to or reference this Privacy Policy. The Software, the Websites, and any other CAVE products or services that link or refer to this Privacy Policy are collectively referred to as the “Service.” This Privacy Policy describes how CAVE collects, discloses, stores, transfers, and uses information that could individually identify our users (“Personal Data”) in connection with our Service.

This Privacy Policy does not apply to the practices of third parties, as explained in more detail below. Please note that we are not responsible for any use of your personal information you provide to third-party applications or websites that may be accessed via the Service. We recommend that you review the privacy policy of any third-party applications or websites that you use. In this Privacy Policy, “we,” “us,” “our,” and other similar references mean CAVE, “you” and “your” and other similar references mean any user of the Service, and “CAVE Affiliates” means any parent, subsidiary, member, officer, director, employee, agent, or contractor of CAVE or any entity under common control with CAVE.

This policy applies (i) immediately to new users who use or access the Service on or after the Effective Date and (ii) on the Effective Date to users who use or access the Service before the Effective Date.

Please contact us if you have any questions or comments about our privacy practices. You can reach us online at info@thecaveapproach.com or by mail at the address listed in the “Addressing Questions Regarding Your Personal Data” section below.

TRANSFERS OF PERSONAL DATA

The Service is hosted and operated in Greece, state member of “E.U.”, with development, support and maintenance operations soon coming in other countries too, through CAVE and its service providers. If you do not reside in the Greece, laws in Greece may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Greece in Greece, and will be hosted on Greek or other E.U. or US servers, and you authorize CAVE to transfer, store, host and process your information to and in Greece, EU countries, US and possibly other countries. You hereby consent to transfer your data to the Greek pursuant to either, at CAVE discretion, the EU-U.S. Privacy Shield Framework, the details of which are further set forth below, or the standard data protection clauses promulgated by the EC, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087

EU PERSONAL DATA

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. CAVE will be the controller of your Personal Data processed in connection with the Service, unless you access the Service through an enterprise account, or other CAVE account that is controlled by a third party (e.g. your employer).

COLLECTION OF PERSONAL INFORMATION

Types of Personal Data We Collect

CAVE collects Personal Data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our Service), service providers (such as our advertising service providers) provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:

• Contact Information:information we collect to identify or contact you. It refers to typical “business card information” such as your first and last name, physical address, email address or telephone number. For example, this is the basic information that we collect when you register for our Service.
• Demographic information:information we collect about your age, your interests in relation to which you are using our Service, your academic background, your nationality, your family status, your health condition, your overall quality of life. For example, this is the information that we collect when you register for the completion of the CAVE Questionnaires.
• Financial Account Information:information that you provide in connection with your purchase of the Service (or a purchase made through the Service), including credit card number, credit card expiration date, credit card verification code, bank account number, bank account title, bank name, branch location, and routing number. You must only provide us with Financial Account Information for accounts and credit cards that you have the lawful right to access.
• Transaction Information:information related to transactions you conduct on the Service, including when you register for a webinar, event or download special content, and your interactions with the Service (for example the functionality you use and the links clicked on the Service).
• User Account Information:information that identifies you to the Service, such as your user name, email address, password, and IP address. For example, we use this information to authenticate you when you log in to the Service, and use the IP address to help maintain your web session security while using the Service.
• Partner Information:information that our business partners, such as our content-providing partners, share with us -- for example, if you use their services to purchase, preview, and/or otherwise use their content when using our Service.
• Log Data:information automatically recorded by the Service about how a person uses our Service, such as IP addresses, device and browser type, operating system, the pages or features of our Website or Service to which a user browsed, the time spent on those pages or features, the frequency with which the Service is used by a user, search terms used by a user, the links on the Service that a user clicked on or used, and other statistics.
• Produced Data:information automatically generated by the Service based on the person’s input such the CAVE Reports.

We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.

We collect Personal Data when a user (i) creates an account (a “User Account”); (ii) logs into the Service; (iii) interacts with the Service; (iv) uploads or generates User Content; (v) communicates with us; and (vi) responds to a communication or interaction from us. Some of the methods and tools we use to collect Personal Data are:

• Unique Identifiers:We use unique identifiers such as cookies, e-mail or your pseudonymized customer ID to track individual usage behavior on our Service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our Service on an individual basis.
• Mobile Device Identifiers:Mobile device identifiers are identifiers stored on your mobile device that track certain data and activities occurring on or through your device. Mobile device identifiers enable collection of Personal Data (such as media access controls) as well as non-personally identifiable information (such as usage and traffic data).
• Cookies, Web Beacons, and Other Tracking Tools:We and our third party service providers collect information about you, your device, and your use of the Service through cookies, clear gifs (a.k.a. web beacons/web bugs) (“Web Beacons”), and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature, and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the Service.
• Cookies:Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service. Cookies are small data files that a website you visit may save on your computer or handheld device that usually includes an anonymous unique identifier. We may include small graphic images in our email messages and newsletters to determine whether the messages were opened and the links were viewed. Third-party advertisers may also create and access cookies, which will be subject to their privacy policies – we accept no responsibility or liability for the use of such third parties’ cookies. If you do not wish cookies to be placed on your PC or handheld device, then they can be disabled in your web browser. The option to do so is normally found in your browser’s “security settings” section. Please note that permanently disabling cookies in your browser may hinder your use of our Websites as well as other websites and interactive services. For more information on cookies, including how to control your cookie settings and preferences, visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/ and http://www.allaboutcookies.org/ and review our Cookie Policy.
• Web Beacons:Web Beacons help us better manage content on our Service by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send. Web Beacons also allow us to enhance our Behavioral Advertising (defined below), which is further discussed below in the section titled “Online Behavioral Advertising” below.
• Social Media Widgets:Some parts of our Service may include social media features, such as the Facebook “like” button, and widgets, such as the “share this” button. These social media features are either hosted by a third party or hosted directly on our Service. When you use these tools, the party that provides the tool, the third party that operates the social media services, and/or we may receive Personal Data about you. By using these tools, you acknowledge that some information, including Personal Data, from your social media services will be transmitted to us, and that information is therefore is covered by this Privacy Policy, and some information, including Personal Data, may be shared with the third party services, and that information is therefore governed by their privacy policies.
• Third Party Sources:We may use third-party services, such as open search tools and social networks, to obtain information about you (such as your name or company) and to enrich your personal information by obtaining publicly available information about you, such as your job title, employment history and contact information.

You may withdraw your consent at any time by emailing us. We will return or destroy your personal information within five days of receipt of your withdrawal of consent.

USE OF PERSONAL INFORMATION

CAVE uses Personal Data to: (i) provide, administer, and improve our Service; (ii) better understand your needs and interests, and fulfill requests you make; (iii) promote scientific research; (iv) personalize your experience; (v) provide Service announcements; (vi) provide you with information and offers from CAVE, CAVE Affiliates, and our business partners; (vii) protect, investigate, and deter against fraudulent, harmful, unauthorized, or illegal activity and (viii) comply with legal obligations.

For example, we use Personal Data to:

• Operate and improve the Service
• Learn more about our users and their internet behaviors
• Target offers to users
• Facilitate communications among and between users and the public in general
• Evaluate eligibility of customers for certain offers, products, or services
• Evaluate the types of offers, products, or services that may be of interest to users
• Provide user support
• Communicate with users regarding support, security, technical issues, commerce, marketing, and transactions
• Facilitate marketing, advertising, surveys, contests, sweepstakes, and promotions
• Facilitate scientific research
• Administer the Service, User Accounts, and transactions with respect to User Accounts
• Enforce our contracts, administering and carrying out our obligations under contracts, and complying with the law
• Publish aggregated data about usage trends, which may be derived from Personal Data
• Complete corporate transactions such as mergers, sales of assets, or bankruptcies

PROCESSING GROUNDS

We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data:

• Contact Information
• User Account Information
• Financial Account Information
• Transaction Information
• User Content

Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:

• Contact Information
• Demographic Information
• Financial Account Information
• User Account Information
• Transaction Information
• User Content
• Partner Information
• Log Data
• Produced Data
• Examples of these legitimate interests include:
  • Operation and improvement of our business, products, and services
  • Marketing of our products and services
  • Provision of customer support
  • Protection from fraud or security threats
  • Compliance with legal obligations
  • Completion of corporate transactions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent (such as the use of your demographic data to facilitate research that promotes Sustainable Development), it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

We use personal information to allow us to process your service requests, provide access to privileged areas of the Websites, send out newsletters, personalize your visit to our Websites, personalize your use of our Products, and enable us to improve the products and services we offer. We may occasionally carry out market research and send you details of services and offers that we think may be of interest to you. If you do not wish to receive such information, please contact us, alternatively, when we send you an e-mail, it will contain a provision for you to opt out of receiving any further information from us.

DISCLOSURE OF PERSONAL INFORMATION

We may provide information about you to our employees, third party service providers and agents in order to administer any accounts, products and services provided.

These parties include:

• Third parties who act for us or provide services for us, such as billing and credit card payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting, and database management services
• Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance, and corporate governance
• CAVE Affiliates, including persons or entities that acquire some or all of CAVE or our assets
• Co-sponsors and presenters of webinars and events that you attend

We also share Personal Data with third party service providers and agents when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Other users (when you use a “share link” to post information publicly, share or comment on content, or as otherwise necessary to effect a transaction initiated or authorized by you through the Service)
• Social media services (if you interact with them through your use of the Service)
• Third party business partners who you access through the Service
• Other parties authorized by you
• The owner and administrator(s) of the Service account that you use, or of the email address that you used to register with the Service (see “Use of Third-Party E-mail Address” immediately below).

We share Personal Data with presenters, sponsors, or other conference participants or organizers if you register for or attend a conference we are involved with.

We share Personal Data with research centers and academic institutions, scientists and authorized personnel involved in research projects to facilitate scientific research.

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, or third parties, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

We also share information with third parties when you have given us consent to do so.

Use of Third-Party E-mail Address

If you register for the Service using an e-mail address that we recognize to be either a part of a third-party enterprise account for the Service (an “Enterprise Account”) or a potential enterprise Service purchaser (for example, your employer’s) (each, an “E-Mail Holder”), we may provide your name and email address to the E-Mail Holder and their administrator. In some cases, we will also consolidate your account(s) with the accounts of the E-Mail Holder and we provide your E-Mail Holder and their administrator with access to your User Account information. This may happen when the E-Mail Holder’s account is established after you register for your individual User Account. We make these transfers to allow users who are part of a larger organization to take advantage of the special features and security enjoyed by our enterprise Account holders, and in order to help you and your organization comply with its internal security and email usage obligations. Please note that all accounts for the Service, and all applicable subaccounts (which may include your User Account), are controlled by the account administrator. In certain cases (e.g. when we are aggregating all of the accounts under a current or potential Enterprise Account), we will provide you with the ability to opt-out of consolidation with an E-Mail Holder’s Account (typically by changing the email address on your account to a non-E-Mail Holder email address).

Additionally, when an E-Mail Holder creates an Account, we may notify any individuals already using the Services under an email address with the same company domain as yours so that they can be migrated to your enterprise Account.

Business Transfers

CAVE may sell, transfer, or otherwise share some or all of its business or assets, including your Personal Data, in connection with a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of CAVE or its assets may continue to use your Personal Data as set forth in this Privacy Policy. You will be notified via email and/or a prominent notice on our Website or Service of any change in ownership or resulting change in uses of your Personal Data, as well as any choices you may have regarding your Personal Data. Similarly, if you access the Service as part of a third party Enterprise Account, the individual or entity controlling the Enterprise Account may transfer or otherwise share the account (including your User Account, User Content, and Personal Data) to an acquirer of some or all of its assets in connection with the migration to an E-Mail Holder’s account, or a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy.

YOUR PRIVACY CHOICES 

Opting Out of Tracking Tools and Behavioral Advertising

You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.

Service Provider Opt Out: You can opt-out directly from some Advertising Service Providers and providers of Tracking Tools by using their opt-out tools. Some of these service providers, and links to their opt-out tools, are:

• Google Analytics: with a privacy policy at http://www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout.
• Industry Opt Out Tools: Some Advertising Service Providers or providers of Tracking Tools may participate in the Network Advertising Initiative's (NAI) Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and you can opt-out of certain services and learn more about your choices by visiting the links included there. Users in the EU can visit http://www.youronlinechoices.eu/ for more information about your choices and to opt out of participating service providers.
• Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
  • Delete existing Tracking Tools
  • Disable future Tracking Tools
  • Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set

Mobile Opt Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en). For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device, as applicable.

Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.

Our Cookie Management Tool: We also allow you the ability to opt out of certain types of Cookies by clicking on the cookie banner when you first enter the applicable website (for EU users), or by using the solution below:

Please note the following with respect to opting out of Behavioral Advertising:

• Some opt-out features are cookie-based, meaning that when you use these opt-out features, an “opt-out” cookie will be placed on your computer or other device indicating that you do not want to receive Behavioral Advertising from certain companies. If you delete your cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.
• Opting-out of Behavioral Advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Service.

Emails: We will give you the ability to opt-out of marketing-related emails by clicking on a link at the bottom of each such email. You cannot opt-out of receiving certain non-marketing emails regarding the Service.

Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at info@thecaveapproch.com. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service.

SECURITY

All security on our Websites is treated seriously. Where applicable, we undertake security steps, including use of SSL technology, on our back-end systems that store customer account information and to protect data transmissions. However, this is not a guarantee that such data transmissions cannot be accessed, altered or deleted due to firewall or other security software failures. To the extent the Service requires you to provide any Financial Account Information, such as when you purchase subscriptions to the Service, that information will be collected and processed by third-party PCI-compliant service providers. We do not store Financial Account Information transmitted through the Service, provided that we do store (or our payment processor on our behalf will store) just the last four digits of your credit card number, if you provide this to us, to comply with credit card processing requirements of authorizations, charges and chargebacks.

If you have any further concerns about security, please email our Customer Service team.

DATA RETENTION

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service, and thereafter as set forth in our Service agreement with you (typically 30 days after termination of the Service, or sooner upon request (except as required by law)). In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Data. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

INTERACTIONS WITH OTHERS

This Privacy Policy applies only to the Service. It does not apply to products, services, or sites that are provided by or operated by third parties, even if such products, services or sites are linked or redirected to or from the Service (“Third-Party Sites”), regardless of whether or not such link or redirection is authorized by CAVE. Third-Party Sites may have their own policies regarding privacy, or no policy at all. The fact that we link to a Third-Party Site is not an endorsement, authorization, or representation that we are affiliated with that third party. CAVE is not responsible for Third-Party Sites, and you use them at your own risk. We encourage you to read the privacy policies and terms of the Third-Party Sites that you visit or use.

The Service contains areas where you may be able to publicly post information, communicate with others, submit media content, and/or review goods, services, or vendors, such as discussion boards or blogs. Any information, including Personal Data that you post there, will be public and can be viewed by the public at large, and therefore anyone who accesses such postings will have the ability to read, collect, and further disseminate such information. We have no control over, and take no responsibility for, the use, storage, or dissemination of information posted or otherwise made available on such portions of the Service. By posting Personal Data online in public forums, you may receive unsolicited messages from other parties.

RIGHTS AND CHOICES YOU HAVE REGARDING YOUR PERSONAL DATA

Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights

You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up-to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

If you are a CAVE Account holder, you can accomplish most of the following by logging into your User Account or, for those using enterprise accounts, by contacting your account administrator. For any further information, requests or questions, please contact us at info@thecaveapproach.com

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

For the following, please email us at info@thecaveapproach.com:

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

You also have the right to lodge a complaint about CAVE practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Closing Your Account

You may close an account, and upon termination of your User Account, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, CAVE may nevertheless retain your Personal Data to protect the business interests of CAVE, CAVE Affiliates, vendors, and other users, and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.

ENFORCEMENT AND RECOURSE

We take our privacy commitments very seriously. We will conduct internal audits of our compliance with this Privacy Policy, and work to ensure that our employees and service providers also adhere to the Privacy Policy. If you have any questions or concerns regarding privacy related to the Service, please send us a detailed message to info@thecaveapproach.com and we will try to resolve your concerns.

POLICY CHANGES

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting) or on the Effective Date set forth in the modified Privacy Policy. In all cases, your continued use of the Service or Website after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

CHILDREN

Our Service is not intended for children under the age of 16 (in the EU), and therefore, CAVE does not knowingly acquire or receive Personal Data from children under the age of 16 (in the EU). If we later learn that any user of our Service is under the age of 16 (in the EU), we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.

FOR FURTHER QUESTIONS REGARDING YOUR PERSONAL DATA

Please, feel free to contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at info@thecaveapproach.com