Greetings & welcome to Sandwich Trading, LLC, (“Sandwich”). Sandwich works hard to protect your personal information in an effort to keep you in control of your privacy. Therefore, we want you to understand how we may collect, store, use, and protect your personal information.
BY USING OUR WEBSITE, AND ANY RELATED PRODUCTS AND SERVICES (“SERVICES”), YOU ARE AGREEING TO THIS POLICY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT ENROLL IN OR USE THE SERVICES.
Data Processor and Controller
Sandwich Trading LLC
c/o Chief Privacy Officer
151 Calle de San Francisco, Suite 200
San Juan, Puerto Rico
As a Business or controller, we will use personal information about you only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of personal data is in compliance with applicable data protection law, including California’s Consumer Privacy Act (“CCPA”) and the European Union’s General Data Protection Regulation (“GDPR”).
The Information We Collect
The personal information we collect about you helps us manage our relationship with you, primarily by allowing us to respond to your queries, to improve website performance and user experience, provide you our Services, and to keep you updated on any changes to our Website or Services.
When we use the term “personal information” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular individual, consumer or household, or data otherwise described as “personal information” under governing laws. Some information may not be considered personal information, such as publicly available information from federal, state or local records or information that is aggregated or de-identified, such that it cannot reasonably be linked to an individual.
When you sign up for our Services, we collect various types of personal information to establish and maintain your account. Personal information collected currently includes: name, email address. Additional information may be requested throughout the life of the account relationship to meet regulatory and legal requirements. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers to either the EU or U.S. servers corresponding to your location.
The personal information we collect, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties (see “Why and How We Share Information” section below).
For EU Data Subjects
For EU data subjects, we have a lawful basis under the GDPR for each of our processing activities, as further indicated below.
For California Residents
The personal information about you that we collect includes information within the below categories of data. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all of our customers. We do not and will not sell personal information about you, as defined under California state law. We also have not done so for the last 12 months.
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Purpose of Collecting Information
A subset of this data is processed in connection with a number of our operational functions, including to open your account and provide you with other services.
Disclosed for a Business Purpose Over the Last 12 Months?
Types of Third Parties Shared With
We may also use various technologies to collect and store information related to your use of our Services. We may collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
Like other websites, Sandwich uses ‘cookies’. Cookies are small pieces of information that our server places on a visitor’s computer hard drive to optimize the users’ experience by customizing our web page content based on browser type and/or other information, and to enable to the user or more easily communicate and interact with the website and provide us with important information on how visitors use the website. Many web browsers are automatically set to accept cookies. These small files also control how our website is displayed and operates. Cookies serve to make our website more user-friendly, effective, and secure. Company’s use both “session” cookies, which last only until you close your browser, and “persistent” cookies, which last until you or your browser deletes them. Most Internet browsers support cookies; however, users can set their browsers to decline certain types of cookies or specific cookies by configuring their browser’s privacy settings (please refer to your browser’s help function to learn more about cookie controls). Further, users can delete cookies at any time. Note that if you disable cookies entirely, our websites may not function properly, or at all in the case of strictly necessary cookies.
We do not use any cookies.
We do not use any cookies.
What types of cookies do we use?
We do not use any cookies.
How are cookies used for advertising purposes?
Cookies and ad technology such as web beacons, pixels, and anonymous ad network tags help companies serve relevant ads to you more effectively. They also help companies collect aggregated audit data, research, and performance reporting for advertisers. Pixels enable companies to understand and improve the delivery of ads to you, and know when certain ads have been shown to you. Since your web browser may request advertisements and web beacons directly from ad network servers, these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.
We do not use any cookies.
How are third party cookies used?
We do not use third-party cookies.
How do I reject and delete cookies?
Information from Third Parties
When using our Services, you may have the option to provide us with information from third parties, such as Facebook, Twitter, Google, and LinkedIn. We may also acquire information about you from third parties in order to verify your identity, process your transactions, detect and prevent fraud, or other similar purposes.
Information from Children
When you use our Services, we may collect information from your computer or mobile device, such as the unique identification number, the model, operating system and version, your browser type and version, the presence of any device, operating system, or browser add-ons, the times you access our Services, the locations from where you access our Services (attributed based on your IP address, the page you visited before navigating to our Services, and your mobile device’s location services), and your stored contacts.
How We Use Information
- We use your information to provide and improve our Services, including for the purposes of:
- Providing you with the account opening service(s), and customer support as requested or as needed.
- Processing and tracking your transactions.
- Monitoring and analyzing how you and other Users use our Services.
- Improving and building features and services you or other users may want.
- Minimizing fraud and abuse of our Services.
- Communicating with you about changes in our Services, the status and security of your account and data, and administrative information.
- Other reasonable uses related to providing, maintaining, and improving our Services.
Why and How We Share Information
When you sign up for our Services, you are directing Sandwich to share information with third parties as outlined below. The information that Sandwich shares includes both the information that Sandwich collects from you directly and the information that Sandwich collects from third parties. We may provide your information to third parties for business and legal purposes, including for the purposes of:
Providing and improving our Services as previously described.
Meeting the requirements of any applicable law, regulation or legal process, including complying with orders from courts of law, regulatory agencies, and law enforcement.
We will not sell or otherwise give your information to third parties for marketing purposes.
Your Rights Regarding Your Information and Accessing and Correcting Your Information
Depending on where you live, your current jurisdiction and applicable data protection laws, and subject to any relevant restrictions/exemption, you may be entitled to certain rights with regards to our processing of your Personal Information. (Please note: depending on the country you live in and the applicable data protection laws, you may only have access to some of the rights listed below).
Restrictions. You may have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
Portability. To the extent the Personal Data you provide Sandwich is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personal Information is based on your consent, you may withdraw your consent at any time. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Information.
Right to Deletion. You may have the right, subject to some exceptions, to request that we delete Personal Information about you that we have collected or maintain. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with certain products and services or where we are legally required to retain certain information. This right is generally excluded from data kept for archival or back-up purposes.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
Submitting a Request and Verifying Your Identity
You may exercise any of the above rights by contacting us through our website or any of the methods listed under Contact Information below, including by emailing us directly at email@example.com.
Please note that under California law, we are only obligated to respond to personal information requests from the same consumer up to two times in a 12-month period. Under both EU and California law, if an individual makes unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access Personal Data, we may charge a fee subject to a maximum set by law.
Before providing information you request in accordance with these rights, we must be able to verify your identity. In order to verify your identity, you may need to submit information about yourself, including, to the extent applicable, providing answers to security questions, your name, and email. We will match this information against information we have previously collected about you to verify your identity and your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.
If you would like to appoint an authorized agent to make a request on your behalf, you must provide the agent with written, signed permission to submit privacy right requests on your behalf, or provide a letter from your attorney. The agent or attorney must provide this authorization at the time of request. We may require you to verify your identity with us directly before we provide any requested information to your approved agent.
Information collected for purposes of verifying your request will only be used for verification.
If you chose to exercise any of these rights, to the extent that they apply, U.S. state law prohibits us from discriminating against you on the basis of choosing to exercise your privacy rights. We may, however, charge a different rate or provide a different level of service to the extent permitted by law.
How We Keep Your Information Secure
We have designed policies and procedures to protect both your confidentiality and the security of your information, including your nonpublic personal information. We store and process your personal information using internal/third party servers located in secure data centers. Additionally, Sandwich uses firewalls and data encryption.
Despite Sandwich’s efforts to keep your information secure, we cannot guarantee the security of your information. As a result, we strongly encourage you to take action to protect your personal data and any device you use to access our Services. In the unlikely event that we come to learn that either our system or your account specifically has suffered a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by email, text message, phone call, a notice on our website, or any other way, depending on the requirements of applicable law.
Links to Other Sites
We are not responsible for the privacy practices of any third parties or the content of sites that are linked from our Services. We strongly encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.
Do Not Track Signals
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.
Sandwich may collect information regarding your location. You may be able to prevent this collection through your device operating system settings or by following the standard uninstall process to remove our mobile application from your device. Similarly, you may be able to control how your browser interacts with cookies. However, if you remove stored cookies or block them from being set, you may affect the availability and functionality of our Services.
Opting Out of This Policy
We may change this policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Last Updated” date above. We encourage you to review the policy whenever you use our Services to stay informed about our information practices and about the choices available to you. You acknowledge and agree that it is your responsibility to review the Policy. Your continued use of this Site and App, and any offerings made available on the Site after a change is posted, including but not limited to the use of the Services, will constitute acknowledgment and acceptance of the then-published Policy.
Please contact us with any questions or concerns regarding our policy.
151 Calle de San Francisco, Suite 200
San Juan, Puerto Rico