CHATSIE PRIVACY POLICY

 

 INTRODUCTION

Chatsie respects your privacy and is committed to protecting your personal data and the privacy and security of all personal information. 

 Chatsie (or “we”, “us” or “our” in this privacy policy) are a provider of mobile application software. It is important to us that you understand the way in which we collect and process your personal data.

 IMPORTANT NOTE: Except where required to do so by law, we will never disclose any personal information to third parties unless explicitly requested or consented to by you.

Purpose of this privacy policy

 This privacy policy aims to give you information on how Chatsie collects and processes your personal data through your use of the Chatsie App (and all related web sites, applications and online services and tools where this policy is referenced, regardless of how you access or use them) and when you register as a user and interact with us through our services. It also tells you what your privacy rights are and how the law protects you.

We will let you know if other Privacy Policies apply

 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting, or processing, certain types of personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

If you would like any additional information about our services or how the Chatsie App processes your personal data, please contact hello@chatsie.com

     1. Important information and who we are

Contact details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.

Full name of legal entity:    Chatsie Limited a company registered in England (Company Number 13169953) with our registered office address at 27, Monomark House, Old Gloucester Street, London, United Kingdom, WC1N 3AX. 

Email address:                         hello@chatsie.com

Making a Complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to our privacy policy Your duty to inform us of changes to your personal data

We keep our privacy policy under regular review. From time to time, we may update this Privacy Policy and reserve the right to do so. 

We will place a notice online when we make changes to this Privacy Policy

Your duty to inform us of changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Cookies

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 our services may become inaccessible or not function properly. Please see our Cookie Policy [A1] for more details. 

    2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We do not collect and hold your Personal Data other than for the purposes of supporting you in your use of our App. 

The collection, use, storage and transfer of your personal data is limited to:

  1. Data processed where you use the online Chatsie Services in order to control the Chatsie App
  1. Data processed if you ask us to provide support to you.
  1. Other data processed by us as part of your use of the Chatsie App and services 
    •       Technical Data which includes your internet protocol (IP) address, browser type and version, hardware information, time zone setting, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the App.
    •       Usage Data which includes anonymised information about how you use our App, products and services..
    •       Communications Data which includes statistical data we collect on usage and where you provide us with your e-mail address. 

We also collect, use and share other Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 

    3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. This includes personal data you provide when you: (a) access online Chatsie services; (b) request marketing to be sent to you; (c) enter a promotion or survey; or (d) give us feedback or contact us.
  • Automated technologies or interactions. As you interact with the Chatsie App, we will automatically collect Technical Data about your equipment, usage and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

    4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To provide you with services in relation to the Chatsie App
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you in providing the App and Services (a) Identity

(b) Marketing and Communications

(a) Performance of a contract with you.

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how users use our App, products/services)

To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud 

(b) Necessary to comply with a legal obligation

To enable you to partake in a competition or complete a survey

 

(a) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how users use the Platform and to develop and grow our business)

 

To use data analytics to improve our 

App, products/services, marketing, user and partner relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of users for certain services and to keep our services updated and relevant, to develop our business and to inform our marketing strategy)

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of the Platform or any associated services.

    5. International transfers

Where we use other organisations to support your use of our services, we may transfer your personal data outside the European Economic Area (EEA). We have contract terms in place that contain obligations on any third party to safeguard your information (whether in the EEA or otherwise). 

In some countries, for legal or practical reasons, Chatsie may have to store personal information in that country.

Whenever we transfer your personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

If we decide or are obliged to send or store your personal information in a particular country, we will update you and describe the protections we have put in place.

    6. Data security and Location

 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

We always keep personal information in secure locations within the EU with strict access controls.  

In addition, we limit access to your personal data to those employees and other third parties who strictly need to know. They will only process your personal data on your instructions and they are subject to a duty of confidentiality.

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

    7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to provide the Services you have requested. 

We may retain certain of your personal contact data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please e-mail hello@chatsie.com

You have the right to: 

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

For some of our products and services you can delete your account or certain information from within the product / service.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    •  If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

 What we may need from you

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.

 Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated.

    9. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to Chatsie, that is the performance of our agreement with you to make the App and its services available. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 External Third Parties 

  • Service providers acting as processors who provide our IT and system administration services.
  • Providers of our cloud services such as AWS, Azure and Google.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

    10. Cookies

Our services use cookies to distinguish you from other users of our services. This helps us to provide you with a good experience when you browse our website and also allows us to improve our services.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our services. They include, for example, cookies that enable you to log into secure areas of our web site such as your account.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our services when they are using it. This helps us to improve the way our web site works, for example, by ensuring that users are finding what they are looking for easily.
  • Targeting cookies. These cookies record your visit to our services, the content you have visited and the links you have followed. We will use this information to make our services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table at: https://cookie-script.com/cookie-report?identifier=a2c4f8677fddb4fd80e789ac96a09fe9

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

    11. Dates of changes to this policy