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Privacy policy

Last updated: October 17, 2018

  1. About Us

    We are Groundspeak, Inc., the owner and operator of the following websites, apps and discussion forums:

    For the purpose of this privacy policy, we refer to the services provided by us in relation to each of the above as our "Services". References in this privacy policy to "we", "us," or "our" are references to Groundspeak, Inc.

  2. How to contact us

    If you have any questions about this privacy policy, or about the personal information we hold about you, you may contact us by clicking here.

  3. About this privacy policy

    When you use our Services, we collect personal information about you. The purpose of this privacy policy is to explain the types of information we collect, and how we use them.

    This privacy policy is divided into the following sections:

  4. What personal information do we collect about you?

    Personal information you give us

    We collect and store the following personal information you give to us when you interact with us or our Services, including when you access our Services through applications provided by third parties (“Authorized Developers”) that connect with our websites using our software interface, known as an API.

    When you create an account with us, or when you use our Services, we collect and store:

    • Account details (including your name, email address(es), passwords, and other identification information).
    • Profile information you provide such as your location, your home location, your profile photo, your cover photo, any other photo uploads, your “about” me information, your Forum title and Forum signature, etc.
    • Information you provide to us when you sign up to receive our newsletter or other communications from us.
    • Information you provide when you enter a competition, prize drawing, or other promotion (for example, your name, email address, address, and other contact details, such as your telephone number).
    • Content and information you provide through the Geocaching Forums, your geocache and trackable logs, or by email to us.
    • Email addresses of people you know when you participate in a referral program.
    • Messages you send or receive through our communications Services.
    • Information you provide to us if you apply for a job, including information in your resume or application form.
    • Any information you provide as part of a survey.

    Personal information we collect automatically

    When you use our Services, we automatically receive and record information from your browser or mobile device for purposes of providing you Services that are personalized, relevant and useful to you:

    • Your location.
    • The unique identifier for your mobile device.
    • Your IP address.
    • Time and date of access ofthe Services.
    • The name of the application you're using if you're accessing our Services through the application provided by one of the Authorized Developers.
    • Your user ID for the account through which you are accessing our Services.
    • Membership data, including whether you are a Premium or Basic member.
    • Your search data, including the latitude and longitude of any location-based search you perform.
    • Files, listings, and content that you access.
    • Which version of our application you're using.
    • Cookie information (click here to find out more information about how we use cookies).
    • Information about the pages you request.
    • If you choose to link your account with us to your social media account (e.g. Facebook), we may collect personal information about you through your social media account.
  5. How do we use your personal information?

    We use your personal information for the following purposes:

    • To provide our Services to you and to administer your account with us.
    • To authorize, process, and track payments and through secure third party credit card and payment processing gateways.
    • To enable your Premium membership status and follow up with you in connection with your membership.
    • Communicating through any of our communications Services.
    • For our own internal business purposes, such as analyzing the use of our Services (via services like Google Analytics and others), market research, and website and mobile application optimization.
    • To enable Authorized Developers to provide geocaching-related websites and applications that extend and enhance the geocaching experience beyond our Services.
    • To communicate with you about things we think will be of interest to you such as our products and Services, and location-based entertainment-related activities.
    • To verify your identity.
    • To provide customer service and review issues with your account or your use of our Services.
    • To enable other users to receive and enjoy the Services.
    • To allow you to share your experiences using our Services with others.
    • To update you on changes to our Services, this Privacy Policy, or our Terms of Use and other administrative communications.
    • To improve our products and Services.
    • To customize the content available through our Services.
    • To allow you to login and share information through a social network site account, such as Facebook and Twitter.
    • To create a convenient and easy-to-use shopping process on Shop.Geocaching.com that includes an online shopping cart.
    • To restrict access to our Services or communicate with users who have violated our Terms of Use Agreement, or otherwise violated our rights or the rights of others.
    • Sometimes, websites that link to or from our Services may collect personal information about you, including any social networking sites to which you choose to link your account.
  6. What is our legal basis for using your personal information?

    If you are accessing our Services in Europe, then applicable law requires us to ensure that we only process your personal information where we have a legal basis to do so. When we process your personal information, we will only do so where at least one of the following applies:

    • We need to use your personal information to perform our responsibilities under our contract with you (e.g. processing payments for Services, and administering the Services);
    • If it is in our legitimate interests and/or those of third parties to use your personal information. For example, it is in our legitimate interests to use your personal information to improve our website, to preserve the historical record of the game for other users, to allow our Authorized Developers access to geocache and public profile data to create websites and applications that extend the geocaching experience beyond what we are able to provide, to preserve other user’s messages, to ensure that our Services are secure, to tell you about new Services, products or offers, and to develop our business; or
    • Sometimes we will ask for your consent to use certain types of personal information, such as by asking you to tick an online box or when you sign up to access certain geocaching related services including those provided by our Authorized Developers. In these circumstances, your consent will be our legal basis for processing your personal information for those purposes. If you have provided consent, you may withdraw it at any time. You may do this by "opting out" where we give you the opportunity to do so, by changing your profile settings, or by contacting us using the contact details below.
  7. With whom do we share your personal information?

    Except as provided below, we do not share or sell information that identifies our users personally or makes it possible for other parties to contact them directly.

    We share your information as follows:

    Who Why do we share it?
    Other users

    When you create an account, we make your username and certain details about your membership, such as whether you are Basic or Premium, when you joined and when you last visited the site, and your finds, hides, and trackable count available for other users who may want to add you as a friend in our system or understand your experience and activity level for purposes of determining your credibility or engagement level with the game.

    If you choose to include personal information (such as your email address, photo, location, or other details) in your public profile, this may be viewed by other registered Geocaching account holders who use our Services for purposes of enhancing the community aspects of the game.

    Any information or content you post publicly will be shared with other users when you use the public features of our services; for example, when you log a geocache, post a photo in your gallery or participate in the Geocaching Forums for purposes of maintaining a historical record of game-related activity and enhancing the community-oriented nature of the game.

    If you choose to participate in a discussion forum, your IP address may be shared with forum moderators (who are also users) to help them provide appropriate controls on forum discussions.

    Authorized Developers

    Publicly available profile information, geocache and trackable logs (including photos) will be accessible to Authorized Developers and users of their services unless you have opted out of sharing with Authorized Developers in Account Settings.

    If you opt out of sharing with Authorized Developers in Account Settings, the users of their services will still be able to see your geocache and trackable logs associated with a particular geocache or trackable (which will include your username and any information that identifies you that you have put into your log) but will not be able to view your profile information.

    Additional information such as your home location will be available to Authorized Developers if you use their application and consent to sharing your account information with them.

    Authorized Developers use this information to develop their own geocaching-related websites and applications to enhance your geocaching experience and the geocaching experience of other registered Geocaching account owners.

    These services are owned and operated by the Authorized Developers and not by us. Authorized Developers will have their own privacy policies in relation to personal information. For a list of our featured Authorized Developers, click here. For a full list, please contact us with a request.

    Other partners

    We provide location information to our map providers without identifying you specifically for the purpose of enabling map functionality.

    Additionally, we may partner with other companies/organizations to provide trackable and other promotions, GeoTours, and Geocaching Adventures. If you choose to participate, the information you provide may be shared via our API or otherwise to enable your participation and to allow the sponsor to learn more about the location of participants. In some cases, with your explicit consent, partners may also use your information to contact you. Their use of your information will be covered by their privacy policy.

    Social media If you choose to log in to your account with or through a social networking service, Groundspeak and that service may share certain information about you for purposes of authenticating your login information. With your permission, we also may share information about your activities on our services with that social network’s users, such as if you choose to post your geocache log on your Facebook or Twitter account.
    Third party service providers From time to time, we employ other companies and individuals to perform specialized functions on our behalf, such as analytics, secure credit card processing, and email services. They may have access to personal information needed to perform these functions but will be prohibited from using it for other purposes.
    Third parties for legal reasons

    We may share your personal information with others if the law requires us to, or if we reasonably believe it is necessary to comply with the law.

    We may also share your personal information if we need to do so to protect or defend our legal rights, or those of our users.

    Third parties for business reasons

    In the unlikely event that we wished to sell our business, we may need to share your personal information with a potential buyer.

    From time to time, we may also share your personal information with members of our group of companies, for example, if we were reorganizing our business.

    Providers of online analytics services We use third party tools such as Hotjar and Google Analytics to track how groups or categories of users interact with our Services. We enable Google Analytics’ User-ID feature to better understand how users interact with our Services over an extended period of time, from different devices and multiple sessions, so we can continue to improve our Services and provide the best experience for our users. User ID is an anonymous identifier that helps identify unique users across multiple devices and browsers. When you log-in to use our Services, your User ID is sent to Google.
    Our suppliers and subcontractors We may also share your personal information with suppliers and subcontractors to enable us to provide Services to you (for example, if you have ordered goods online, we may share your personal information with delivery companies).
  8. What rights do I have in relation to my personal information?

    Your rights in relation to how we use your information

    You can choose how we use your personal information in the following circumstances:

    • You can add, update, or delete certain personal information by signing in to your account and accessing your Account Settings. Click here to find out more about how to do delete information from your profile and here to find out more about how delete your geocache and trackable logs.
    • You can choose to opt-out of allowing our Authorized Developers to share your Geocaching.com public profile with their users by changing your Authorizations in Account Settings.
    • If you do not want to receive our newsletter or marketing messages from us, you can click the "unsubscribe" link at the bottom of the email or message you receive adjust your email preference in Account Settings.
    • If you do not want to receive emails from us about specific geocaches or trackables, you can change your preferences by logging into your account and removing these geocaches and/or trackables from your Watchlist or Lists Click here to find out more about how to do this. Please note that you cannot disable notifications related to geocaches or trackables owned by you.
    • If you have granted us access to your Facebook or Twitter account by linking, you can disconnect the link by logging into your account, accessing your profile and clicking the Facebook or Twitter icon to disconnect. Click here to find out more about how to remove app and social media authorizations.

    If you choose not to provide personal information, we may not be able to provide you with our Services, or certain aspects of our Services.

    Other rights in relation to your personal information if you are accessing the Services in Europe:

    In addition to the choices described above you also have the following rights under the European General Data Protection Regulation (“GDPR”) if you are accessing the Services in Europe:

    • Right of access to your Personal Data (Art. 15 GDPR): You have the right to ask us for confirmation on whether we are processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved). “Personal Data” is defined in the GDPR as any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
    • Right to rectification (Art. 16 GDPR): You have the right to have your Personal Data corrected, as permitted by law.
    • Right to erasure (Art. 17 GDPR): You have the right to ask us to delete your Personal Data, as permitted by law. This right may be exercised among other things: (i) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) when you withdraw consent on which processing is based on your consent and where there is no other legal ground for processing; (iii) when you object to processing which is necessary for our legitimate interests (pursuant to Art. 21 (1) GDPR) and there are no overriding legitimate grounds for the processing, or when you object to your Personal Data being used for direct marketing purposes (pursuant to Art. 21 (2) GDPR); or, (iv) when your Personal Data has been unlawfully processed.
    • Right to restriction of processing (Art. 18 GDPR): You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested; when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead; (and, when you have objected to processing which is necessary for our legitimate interests (pursuant to Art. 21 (1)) GDPR pending the verification whether the legitimate grounds of Groundspeak override your grounds.
    • Right to data portability (Art. 20 GDPR): You have the right to receive the Personal Data that you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
    • Right to object (Art. 21 GDPR): You have the right to object to our processing of your Personal Data, as permitted by law. This right is limited to processing which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or processing which is necessary for the purposes of our legitimate interests (Art. 6 (1) (e) or (f) GDPR), and includes profiling based on those provisions, and processing for direct marketing purposes.

    Contacting us to exercise your rights and with any questions

    If you need help or wish to exercise any of the above rights or have questions about them, please email us by clicking here, or write to us at Geocaching HQ, 837 N. 34 th Street, Suite 300, Seattle, WA 98103. For specific requests to remove or change your profile information on Shop Geocaching (shop.geocaching.com), please email Shop Geocaching directly via https://shop.geocaching.com/default/contact.

    We will consider all such requests and provide our response as soon as we can. Please note, however, that some personal information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your personal information for our legitimate interests, to protect the privacy of others, or to comply with a legal obligation. Please note that we may request you provide us with information necessary to confirm your identity.

  9. How long do we keep your personal information?

    If you want to permanently delete your account or following your explicit request for deletion of any of your personal information, we will delete your account and/or help you to delete your personal information as requested. Due to the nature of the game and the way that users interact, you will need to take all steps necessary to facilitate the deletion, including adopting or removing any geocaches you own and disabling your account. We will then complete the deletion process as soon as possible. The way our systems are structured, in some cases, it may take up to 30 days for records to be deleted or overwritten. In some circumstances (set out below) we may keep your personal information for longer.

    If you stop playing or temporarily disable your account, without taking any further steps or asking us to permanently delete your account or personal information, we will keep your information as long as needed to ensure the integrity of the game and the enjoyment of other players. As an example, if you temporarily disable your account without removing or adopting out your geocaches, we will keep your information until it is clear that your geocaches are no longer available to be found. Your geocache and trackable logs and any images associated with them will remain as part of the historic record of the geocache or trackable with which they are associated unless you delete them or explicitly request the permanent deletion of your account. If you have provided personal information or content which other users need to use in relation to the Services (for example information about a particular geocache you have logged, or placed; if you have moved or logged a particular trackable; or if you have left instructions or goals about a particular trackable) we may retain that information for as long as we need to provide the Services to our other users but we will delete the information or help you to delete the information upon your request. For more information about trackables please click here.

    We know that sometimes users take a break from the game and come back at a later time, which is why we don’t automatically permanently delete your account and personal information if you stop playing or temporarily disable your account. We will contact you if you have stopped playing or temporarily disabled your account to check if you would like us to permanently delete your information. Please note that once your account and personal information has been deleted we cannot get it back. If you don’t ask us to permanently delete your account and personal information, we will keep it until you want to reactivate your account and we will store it securely and in accordance with this privacy policy.

    If you have provided us with personal information for a specific purpose, we will keep your personal information for as long as we need to fulfill that purpose. For example, if you have provided address information as part of a competition entry, we will keep that information for as long as necessary to administer the competition.

    We will retain your contact details if you have an account with us or if we think you may be interested in marketing messages, offers, promotions, or new Services. You will always have the choice of opting out of receiving these messages. If you do so, we will remove you from our email marketing lists as soon as we can but within 10 business days.

    If you have posted content online in the Geocaching Forums, we will retain that content for as long as we think the topic is relevant. After this time, we may delete the post or archive it.

    Where we have obtained personal information automatically about your use of our apps or website (e.g. analytics), we will keep this information for as long as we feel it may be useful to us to improve and develop our business. We will delete it when it is no longer useful. This will normally be within 24 months of completion of the purpose for which it was originally collected. As an example, we may conduct a test for two months during which one group of users is shown our current home page and one group is shown a new version of our home page to determine which is preferable to users. Twenty-four months after completion of the two-month test, we would delete personal information associated with the test.

  10. How do we protect your personal information?

    Groundspeak has implemented many security measures to protect against the loss, misuse, and alteration of your information. We protect your account information through the use of a password. To protect the confidentiality of your information you MUST keep your password confidential and not disclose it to any other person. We also work to protect the security of your credit card information during transmission through the use of third party payment processors using Secure Sockets Layer (SSL) software, which encrypts the information you input. However, keep in mind that no security measures are perfect or impenetrable.

  11. Transfers of your personal information outside the European economic area

    If you are accessing our Services from Europe, then the Personal information which you provide to us, or which we collect about you, will in most cases be stored and processed in the U.S.

    In order to ensure your personal information is protected we have signed up to the EU-US "privacy shield" framework. Please click here to see our Privacy Shield Policy, which will apply to all personal information transferred to the U.S. Please click here to find our more information about the privacy shield framework.

  12. Do I have to be a certain age to use the services?

    Our services are not intended for use by children under the age of 13. If we learn that personal information of someone less than 13-years-of-age has been collected through our services, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained an account then you may alert us via email and request that we delete that child's personal information.

  13. Complaints and questions

    If you have any complaints or questions about how we use your personal information, you may contact us using the contact details set out above. We will then get in touch with you to see how we can help.

    If you have a complaint about how we use your personal information, we would always prefer you to contact us first. However, you may also make a complaint to the data privacy regulator if you wish to do so. If you would like more information about how to contact the relevant data privacy regulator, please contact us.

    Details of our EU data protection officer and EU-based representative

    We are located in the U.S. However, we have an EU based data protection officer and EU-based representative whose details are as follows:

    Email: DPO@geocaching.com

    Address: Osborne Clarke, ATTN: Groundspeak, Inc. DBA Geocaching Data Protection Officer, Innere Kanalstr. 15 50823 Cologne, Germany

    Our EU-based representative, MCF Legal Technology Solutions Limited, can also be contacted at: Email: EURepresentative@geocaching.com

    Address: MCF Legal Technology Solutions Limited, ATTN: Groundspeak, Inc. DBA Geocaching EU Representative, Riverside One, Sir John Rogerson's Quay, Dublin 2, D02 X576

  14. Changes to this privacy policy

    We may amend this Privacy Policy from time to time. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this page. Please review this Privacy Policy periodically to be informed of how we use and protect your information. If we have your email address, we may also email you with information on those changes.

  15. How we use cookies

    A cookie is a small text file that is downloaded onto your computer or smartphone when you use our Services. We use cookies and other similar data collection technologies on our websites and applications.

    Information we collect using cookies

    We collect the following information from you:

    • The date and time you use our websites or apps.
    • Information about your browser, system, or device configuration.
    • Your internet browsing history (including the pages you have viewed)
    • Your IP address.
    • We use third party tools such as Google Analytics cookies, Facebook pixel, Localytics and Hotjar to track how you interact with our apps and websites, and the pages you visit.

    How we use cookies information

    We place cookies and other tracking technology that identifies you, or allows third parties to do so on our behalf, for the following purposes:

    • To provide our Services. For example, we use them in order to know your membership status and provide you with the appropriate benefits. We also use them to enable you to sign up for information from us.
    • For system administration and security and to gather general information about our audiences and their geographic locations.
    • To recognize you automatically when you return to our websites and apps and to customize certain features and functions.
    • To understand the type of content you are interested in. We use this information to send you marketing messages, promotions, or offers, or information about Services we think you might be interested in.
    • To make an automated record of your activities on our websites and mobile applications.
    • To manage, track, and follow up on email marketing campaigns.
    • To display ads and messaging specific to your use of our Services when you are on Facebook or on other websites and to understand their effectiveness.

    Disabling cookies

    You can use the tools in your browser to decline, disable, or delete any cookies. You will still be able to log on as a member if you decline or delete our cookie that enables automatic recognition. However, many important features of our websites will not be available (e.g. you will not be able to log a geocache if persistent cookies have been disabled). If you disable the session cookie for our websites, you may remain on the site but you will not be able to use Shop Geocaching and access certain other content.

    Third party advertising cookies

    We allow other companies to advertise on our websites and applications. We do not control their use of cookies or other data collection technologies or practices. Third parties may place cookies on your computer or device so they can send you marketing messages, advertisements, or promotions based on your navigation history.

    Facebook may use information collected through Facebook pixel to customize ads on Facebook and other sites. You can learn more by visiting Facebook’s Data Policy and can control the information shared about you by changing your Facebook ad preferences.

    Google's use of the DoubleClick cookie enables it and its partners to serve ads to you based on your visit to our websites and/or other sites on the Internet. Google and some of the companies it works with may offer additional choices about your preferences. Please visit Google for more information about the technologies it uses, the types of information it collects and its privacy practices. Please visit Google and use "Ads Settings" to set your preferences. The website http://www.aboutads.info offers useful information about ad networks and a single place to turn off targeted ad serving from any of its members. We may add or change the list of third party advertisers from time to time without changing the effective date of the Privacy Policy itself. We recommend you to check this section for changes regularly.

    Although this list may be updated from time to time, most of the cookies we currently use are set out in the following table available here.

    Privacy Shield Policy

    This Privacy Shield Policy (“Policy”) applies to all personal data transferred to Groundspeak, Inc. (“Groundspeak”, “we”, “our”, or “us”) from an organization in the European Economic Area (EEA) (which includes the member states of the European Union (EU) plus Iceland, Liechtenstein and Norway). This Policy sets out our practices for collecting, using, maintaining, protecting and disclosing that personal data. Our general Privacy Policy applies to information that individuals give us about themselves through our websites, applications and services.

    Definitions

    For purposes of this Policy, the following definitions shall apply:

    “Agent” means any third party that collects or uses personal data under the instructions of, and solely for, Groundspeak or to which Groundspeak discloses personal data for use on Groundspeak’s behalf.

    "Groundspeak" means Groundspeak, Inc., which does business as Geocaching and Geocaching HQ, and any predecessors and successors in the United States.

    "Personal data" means any data or set of data that identifies or could be used by or on behalf of Groundspeak to identify (together with other data) a living individual. Personal data does not include data that is anonymized or aggregated.

    "Sensitive data" means any personal data that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data that concerns health or sex life, or data about criminal or administrative proceedings and sanctions.

    EU-U.S. Privacy Shield

    Groundspeak complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU to the U.S., respectively. Groundspeak has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability (“the Privacy Shield Principles”) which are the basis for the principles of this Policy. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

    Principles

    Notice

    Groundspeak receives personal data about individuals in the EEA collected by Groundspeak and partners who promote geocaching and/or use geocaching to promote their products or locations in Europe. Groundspeak uses this personal data to provide services enabling individuals to participate in location-based play and customer support, information updates and purchases related to such services and in geocaching-related promotions. This data also facilitates our partners’ participation in geocaching-related marketing and promotions and enables partners to develop other geocaching services.

    Choice

    Groundspeak will offer individuals the opportunity to choose (opt-out) whether their data is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal data by contacting us at the address given below.

    Groundspeak will not use sensitive personal data for a purpose other than the purpose for which it was originally collected, or subsequently authorized by the individual, without first receiving the individual’s affirmative and explicit consent (opt-in). Groundspeak will treat as sensitive any personal data received from a third party where the third party identifies and treats it as sensitive.

    Accountability for Onward Transfer

    Groundspeak may employ third parties to manage its IT infrastructure, provide credit card processing and customer support, perform analytics, and manage its email service. These entities may have access to personal information if needed to perform their functions for Groundspeak.

    Groundspeak may also disclose personal data – such as public profile information and geocache logs – to non-agent third parties by licensing its application program interface (API) to partners who use it to develop other geocaching-related services. If you wish to opt-out of transfers to such non-agent third parties, please contact us at the address given below or change your authorizations in Account Settings to stop such sharing of data.

    Groundspeak may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

    For data received under the EU-U.S. Privacy Shield, Groundspeak will obtain appropriate assurances from its agents that they will safeguard personal data consistent with this Policy. Examples of appropriate assurances that may be provided by agents include the following: a contract obligating the agent to provide at least the same level of protection as is required by the Privacy Shield, its own EU-U.S Privacy Shield certification, or another European Commission adequacy finding.

    Groundspeak’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Groundspeak remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Groundspeak proves that it is not responsible for the event giving rise to the damage.

    Security

    Groundspeak will take reasonable and appropriate precautions to protect personal data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

    Data Integrity and Purpose Limitation

    Groundspeak will use personal data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Groundspeak will take reasonable steps to ensure that personal data is relevant to its intended use, accurate, complete and current.

    Access

    Upon request, Groundspeak will grant individuals reasonable access to personal data that it holds about them. Groundspeak will take reasonable steps to permit individuals to correct, amend, or delete personal data that is demonstrated to be inaccurate or incomplete. An individual may request access to their data, or otherwise correct, amend, or delete their personal data by contacting us at the address given below or by making changes to their Account Settings.

    Recourse, Enforcement and Liability

    In compliance with the EU-U.S Privacy Shield, Groundspeak commits to resolve complaints about privacy and personal data collection or use. EU individuals with inquiries or complaints regarding this Policy should first contact Groundspeak at the address given below. Groundspeak will investigate and attempt to resolve such complaints by reference to the principles contained in this Policy.

    Groundspeak has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the BBB EU PRIVACY SHIELD web site at www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

    Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

    Groundspeak is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

    Groundspeak will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Groundspeak determines is in violation of this policy may be subject to disciplinary action.

    Contact Information

    Questions regarding this Policy should be submitted to Groundspeak by e-mail to contact@geocaching.com

    Or by postal mail to:

    Geocaching HQ, 837 N. 34th Street, Suite 300, Seattle, WA 98103 USA

    Limitations & Charges

    Groundspeak may also be required to disclose an individual’s personal data in response to a lawful request by public authorities or in connection with a legal obligation. Adherence by Groundspeak to these Privacy Shield Principles may also be limited to the extent necessary to meet national security, public interest or law enforcement obligations, and to the extent expressly permitted by an applicable law, rule or regulation.