Privacy Policy

Last Updated: January 30, 2020

Introduction

Themeco, LLC (referred to as “we”, “us” or “our”) have established this privacy policy to provide you with details of how we collect and process your personal data through your use of our website, theme.co.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@theme.co.

By providing us with your data, you warrant to us that you are over 13 years of age.

What Data do we Collect About You, For What Purpose and on What Grounds We Process It

You can visit our website without revealing any personal data. However, we need certain personal information if you wish to purchase certain products or services, receive email updates from us, or use certain services. Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact forms on our website, through email, text, social media messaging, social media posting or any other communication that you send to us. We process this data for the purposes of communicating with you, for considering job applications, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, processing job applications, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, home address, email address, phone number, contact details, profile photo, purchase details and your partly anonymized card details. We process this data to supply the products and/or services you have purchased, validating product licenses, and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract and/or agreement between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data and Technical Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is our legitimate interests (namely to grow our business).

Recruitment Data which may include your CV or resume, online profile, written application, responses to questions, interview notes and information passed to us from former employers, in addition to any Communication Data listed above. We use this to assess job applications. Our lawful ground for this processing is legitimate interests, which in this case are to find the very best candidates to work for us.

We do not collect any sensitive data about you. Sensitive data refers to data such as your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to provide products or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@theme.co. In case we need to use your details for an unrelated new purpose we will update this privacy policy.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

How We Collect Your Personal Data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties such as analytics providers such as Google, advertising networks such as Facebook, such as search information providers such as Google, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also collect data from publicly available sources such as social media profiles and in the case of job applications, we may also obtain personal data from former employers.

Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is our legitimate interests.

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if:

  • You purchased one of our products or services, or asked for information from us about our products or services; or
  • You agreed to receive marketing communications and in each case you have not opted out of receiving such communications since; or
  • You registered on our site to access products, services, or support. You can opt out of receiving emails from us at any time.

We do not share your personal data with any third party for their own marketing purposes. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

You can ask us to stop sending you messages at any time by following the opt-out links on any message sent to you or OR by emailing us at info@theme.co at any time. However, we caution against this as you may miss out on important product news.

If you opt-out of receiving communication this opt-out does not apply to personal data provided as a result of other transactions, such as purchases or for the fulfillment of services.

Disclosures of Your Personal Data

We may share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Contractors who use your personal data in the course of activities for which they are contracted.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes only.

Transfer of Data

Where we transfer your data to third parties, we will only do so where those parties agree to keep this information confidential. As such:

  • We may transfer data to service providers who are part of the EU-US Privacy Shield; or
  • Where we use certain service providers or contractors, we may use specific contracts or codes of conduct or certification mechanisms that are compliant with both US privacy laws and the EU General Data Protection Regulation.

If neither of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

Unfortunately, no data transmission over the internet can be considered 100% secure. However, your personal and non-personal data is protected for your privacy and security. In certain areas of our websites, as identified on the site, we may use industry-standard SSL-encryption to protect data transmissions.

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees, contractors and partners who have a business need to know such data.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under EU data protection laws, EU citizens have rights in relation to personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights here.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

Under the General Data Protection Regulations (GDPR) we are required to nominate a supervisory authority within the EU for our EU customers. Therefore, if you are an EU citizen and wish to make a complaint regarding our collection and use of your data, we would refer you to the Data Protection Commissioner in Ireland.

However, before making a complaint to any supervisory authority, regardless of your location, we would ask you to contact us first, so that we can try to resolve it for you.

If you object to the collection, use or disclosure of your personal data as outlined in this policy, please do not provide any personal data to us. If you have provided personal information to us but now object to its use or disclosure as outlined herein, please email us at info@theme.co.

This website may include links to third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Cookies

A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyze traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and/or services in response to what you might need or want. Cookies are either:

  • Session Cookies – These are only stored on your computer during your web session and are automatically deleted when you close your browser. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or

  • Persistent Cookies – A persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.

Cookies can also be categorized as follows.

  • Strictly Necessary Cookies – These cookies are essential to enable you to use the website effectively, such as when buying a product or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

  • Performance Cookies – These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.

  • Functionality Cookies – These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymized.

Please note that third parties who advertise on our website (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Changes to This Privacy Policy

From time to time, we may revise this privacy policy as we see fit. When we do, we will also revise the “last update” date, which can be found at the top of the policy. We encourage you to review this policy periodically as we may not provide you with notice of revisions . If you continue to use our website after we have revised this policy, this will signify your acceptance of it.

If you have questions or suggestions about this privacy policy, or your own personal information, please contact us by email, at info@theme.co.

Themeco LLC, 1621 Central Ave, Cheyenne WY, 82001 USA