Owner and Data Controller
DATS APP LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom Owner
contact email: email@example.com
1. Personal Data that the User shares with DATS
1.1. Basic Account Information
1.2. Information available to other DATS Users
Users should be aware of the fact that - while using his/her own account – username and bookmarks (but not e-mail address) will be visible to other Users (please also note that such information will be available even in case the relevant Users are not “following” each other on DATS. Therefore, such information will be visible to all DATS community). In addition, please also consider that none of the information referred to Users might be public.
1.3. Types of Data Collected
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
1.4. How are Personal Data used?
The Owner uses Personal Data to provide Users with its service, and in particular for the following reasons:
- to supply Users DATS services;
- for statistical and management purposes (such as administering the Application or improving its products and services);
- internal record keeping, administrative purposes, and to inform Users about the Owner events, services or products, or other related information that it thinks would be of interest to Users;
- to communicate marketing messages, newsletters and details of DATS business or the businesses of carefully-selected third parties which the Owner thinks may be of interest to Users by post or email or similar technology (Users can inform DATS at any time if they no longer require marketing communications, by sending an e-mail as indicated in Section 6 below).
From time to time, the Owner may also use certain Personal Information to contact Users for market research purposes or to customize the website according to Users’ interests. Users’ information will not be disclosed to any third party unless Users have given their specific consent to such disclosure. Users may at any time request the Owner to refrain from sending marketing messages by sending an email to firstname.lastname@example.org and specifying such request.
1.5. Direct marketing
The Owner may use some of the Data it collects (included those collected by third parties) for marketing purposes. If Users no longer wish to receive marketing messages from DATS or its partners, they may exercise their right to opt-out from receiving such messages by following the instructions included in the message they receive from DATS or by contacting the following e-mail address: email@example.com
2. Details on Personal Data collected
2.1. Basic information
By signing up, Users allow the Owner to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, the Owner will be able to access some Data, stored by these third-party services, for registration or identification purposes. The User registers by filling out the registration form and providing the Personal Data directly to this Application. Personal Data collected are the following:
- email address;
2.2. Location Information
DATS requires information about User’s signup and current location, which the Application gets from signals such as User’s IP address or device settings, to securely and reliably set up and maintain the User’s account and to provide services to the User itself. Furthermore, subject to User’s personal settings, the Owner may collect, use, and store additional information about User’s location - such as current precise position or places where the User has been previously located. Therefore, this Application may collect, use, and share the User’s location Data in order to provide location-based services. Most browsers and devices provide tools to opt-out from this feature by default. If explicit authorization has been provided, the User’s location Data may be tracked by this Application. The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out his current location in the appropriate field and allows the application to detect the position automatically.
In order to operate and provide DATS’ services, the Owner keeps track of how Users interact with links across the services provided through the use of the Application. This includes links in emails DATS sends to Users.
2.4. Usage Data
The Owner receives information when User views content on or otherwise interacts with DATS services. This Usage Data includes information such as User IP address, browser type, operating system, the referring web page, pages visited, location, User mobile carrier, device information (including device and application IDs) and search terms.
2.6. Access the address book
This Application may request access to your address book.
2.7. Additional information about User's Personal Data
2.8. Non-Personal Data
This Application may share or disclose non-Personal Data, such as aggregated information like the total number of times people engaged with the Application, the number of people who clicked on a particular link or bookmarked a specific location (even if only one did).
3. Mode and place of processing the Data
3.1. Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
3.3. Retention time
3.4. The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: access to third party services' accounts, analytics, contacting the User, registration and authentication, managing contacts and sending messages, platform services and hosting, backend infrastructure and location-based interactions. The Personal Data used for each purpose is outlined in the specific sections of this document (please refer to Section 4 below).
3.5. Security and integrity of data
The Owner maintains appropriate administrative, technical and physical safeguards designed to help maintain the security, confidentiality and integrity of Personal Information and to protect it against accidental or unlawful destruction, accidental loss, unauthorized alteration, disclosure or access, misuse, and any other unlawful form of processing of the Data in its possession.
3.6. Data transfer
The Owner may transfer Personal Information to countries outside the European Economic Area (EEA) and, when it does, it will ensure that either the European Commission has issued a decision recognizing the adequate level of protection of Personal Information in the country receiving the Data, or in the absence of such decision, DATS will implement appropriate safeguards to protect the Data that is being transferred.
4. Detailed information on the purposes of processing
User’s Personal Data Please note that Personal Data is collected for the following purposes and using the following services:
4.1. Access to third party services' accounts
This type of service allows this Application to access Data from User’s account on a third party service and perform actions with it. These services are not activated automatically, but require explicit authorization and consent by the User. Such services are:
- Access to the Facebook account (This Application)
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. Such services refer to the following:
- Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected through Google Analytics: Usage Data.
- Facebook Analytics for developers
Facebook Analytics is a web analysis service provided by Facebook for developers. Facebook Analytic utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities
Personal Data collected through Facebook Analytics: Usage Data.
- Facebook pixels
Facebook pixel is a tool for collecting statistical data that allows to measure the effectiveness of advertising by understanding the actions that people perform on a website or application.
Personal Data collected through Facebook Pixels: Usage Data.
- Fabric Answers
Fabric Answer is a web analysis service provided by Google Inc. (“Google”). Fabric Answer utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities
Personal Data collected through Fabric Answer: Usage Data.
4.3. Contacting the User
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected are the following:
- email address
4.4. Managing contacts and sending messages
This type of service makes it possible to manage a Data base of email contacts. These services may also collect Data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message. This service refers to:
- MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC. Personal Data collected thought MailChimp: email address.
4.5. Platform services and hosting
These services have the purpose of hosting and running key components of DATS’s website. Such platforms provide a wide range of tools to the Owner – e.g. analytics, User registration, commenting, Data base management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. More in detail, this service refers to:
- Squarespace (Squarespace, Inc)
Squarespace is a platform provided by Squarespace, Inc. that allows the Owner to build, run and host its website. Squarespace is highly customizable and can host websites from simple blogs to complex e-commerce platforms. Please note that the Owner use this service only with reference to its website. Therefore none Squarespace services are directly or indirectly addressed to the Application.
4.6. Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.
- Direct registration (This Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application. Personal Data collected: username, email address, and password.
5. Additional information about Data collection and processing
The Owner shares or discloses User’s Personal Data with only upon his/her consent or at his/her direction, such as when user authorizes a third-party web client or application to access the relevant account. Subject to the User’s settings, the Owner also provides certain third parties with Personal Data (such as the Data Supervisor) to help the Owner offer or operate its services.
5.2. Legal action
5.3. User legal rights
Subject to applicable law, Users may have a number of rights regarding the processing of Personal Data, including, inter alia:
- The right to request access to, or copies of, Personal Data that the Owner processes or controls, together with information regarding the nature, processing and disclosure of that Personal Data (referring to the Data Subject);
- the right to request rectification of any inaccuracies in User’s Personal Data that the Owner processes or controls;
- the right to request, on legitimate grounds: (i) deletion of Personal Data that the Owner processes or controls; or (ii) restriction of processing of Personal Data that the Owner processes or controls;
- the right to object, on legitimate grounds, to the processing of Personal Data by the Owner or on his behalf;
- the right to have the Personal Data that the Owner processes or controls transferred to another Data Controller, to the extent applicable;
- where the Owner processes Personal Data on the basis of User’s consent, the right to withdraw that consent; and
- the right to file a complaint with a Data Protection Authority regarding the processing of Personal Data by the Owner or on his behalf.
5.4 Affiliates and Change of Ownership
5.5. Information not contained in this Policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
6. Managing Personal Data with DATS
6.1. Accessing or rectifying Personal Data
If the User has registered an account on the Application, the Owner provides the User with tools and account settings to access and correct username and password the User has provided to the Owner and associated with the relevant account. In case the User intends to cancel his/her e-mail address as to eliminate the relevant account on DATS, the User is requested to send an e-mail to the Owner contact e-mail (firstname.lastname@example.org) by specifying his/her request. The Owner will address such request and will notify the User
- by sending a confirmation e-mail
- once the account has been deleted and is not available anymore.
DATS keeps Usage Data for a [maximum of 2 months]. Upon the User’s decision, his/her account – by following the relevant instruction - will be deactivated and then deleted. When deactivated, the User’s DATS account, including nickname, username, bookmarks, will no longer be viewable on the Application. For up to [60 days] after deactivation, it is still possible to restore the previous account if it was accidentally or wrongfully deactivated. Keep in mind that search engines and other third parties may still retain copies of the User’s public information.
6.3. Additional Information or Assistance
6.4. Children and DATS Services
The Application’s services are not directed to children. The User may not use DATS services if he/she is under the age of 13. The User must also be old enough to consent to the processing of Personal Data in the relevant country.
ANNEX I - Definitions and legal references
- “Personal Data (or Data)” means any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
- “Usage Data" refers to the Information collected automatically from this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
- “User” means the individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
- “Data Subject” refers to the legal or natural person to whom the Personal Data refers.
- “Data Controller (or Owner)” means the natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
- “This Application “or “Application” or “DATS” refers to the means by which the Personal Data of the User is collected.
- “Cookies” refers to Small piece of Data stored in the User's device.
Effective: May 25th, 2018
Last update: June 7th, 2018