1. PERSONAL DATA AND IDENTIFICATION INFORMATION
Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process the following categories of personal data about you: names, emails, telephones, addresses, bank information, nationality, gender, date of birth, occupation, photos and videos depicting you.
We may collect personal identification information from Users in a variety of ways, including, but not limited to: when Users make use of the App or visit our Site; register on the site or App; place an order; subscribe to the newsletter; respond to a survey; fill out a form; send us an email; and in connection with other activities, services, features or resources we make available on our Site or App. These methods and the use is outlined below in How We Use Collected Information.
2. IN APP SHARING OF CUSTOMIZED APP DATA
The App, among other things, permits Users to create a customized version of the App (the “User Customized App”) which is accessible to other Users that are invited to download the User Customized App. Each User would have access and a right to use most, if not all, of the information, photographs, video, audio and other material and data that you provide through the use of the User Customized App, some of which is likely to be or include personally identifiable information.
By way of example, if Jane Doe was getting married, she might decide to make use of the App by creating a User Customized App for use by her family, friends and all the other expected guests at her wedding. Ms. Doe and her guests would have access to all photographs, information and other data that you provide through the User Customized App and could elect to share such data with other Users or other third parties.
3. USE OF ADVERTISING ID AND CAMERA
Our App uses Advertising ID to enable push-notification service, whereby Users may be informed about the new information available through the app, e.g. change of the wedding venue. The Advertising ID or push-notifications are not used for advertising or selling any additional services. Our App also uses the camera to enable Users to take and upload photographs to their Customized App. As described above, each User would have access and a right to use the photographs and other information in their Customized App.
4. NON-PERSONAL IDENTIFICATION INFORMATION
We may collect non-personal identification information about Users whenever they interact with our Site or App (including those visiting on an anonymous basis). Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site or App, such as the operating system and the Internet service providers utilized and other similar information.
5. WEB BROWSER COOKIES
6. HOW WE USE COLLECTED INFORMATION
Alexandra Maltseva and Invitations & Co Ltd collects and uses Users’ personal information for the following purposes:
6.1 TO PERSONALIZE USER EXPERIENCE
In some circumstances, we may anonymize your personal data in aggregate for research or statistical purposes to understand how our Users as a group use the services and resources provided on our Site in which case we may use this information indefinitely without further notice to you.
6.2 TO IMPROVE OUR SITE AND APP
We continually strive to improve our offerings based on the information and feedback we receive from you. This information does not include your personal information and is used for future features and services in development.
6.3 TO IMPROVE CUSTOMER SERVICE
Your information helps us to more effectively respond to your customer service requests and support needs. This information is only accessed if you request customer service and technical support.
6.4 TO PROCESS TRANSACTIONS
We may use the information Users provide about themselves when placing an order only to provide service to that order. This information is processed directly through Stripe and we do not process locally in our database. This data is processed to supply the service(s) you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. We do not share this information with outside parties except to the extent necessary to fulfill the order.
6.5 TO ADMINISTER A CONTENT, PROMOTION, SURVEY OR OTHER SITE OR SERVICE FEATURE
6.6 TO SEND USERS INFORMATION
they agreed to receive about topics we think will be of interest to them.
6.7 TO SEND PERIODIC EMAILS
The email address Users provide for order processing, will only be used to send them information and updates pertaining to them and/or the features, services and functionalities requested by or of interest to such User. It may also be used to respond to such User’s inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails and/or text messages that may include company news, updates, product or service information relating to Alexandra Maltseva and Invitations & Co Ltd’s offerings or that of Alexandra Maltseva and Invitations & Co Ltd’s commercial partners. If at any time the User would like to unsubscribe from receiving future emails, User may contact us via support information provided on our Site or contact information below.
6.8 TO DISPLAY EXAMPLES OF OUR WORK
We may use some generic snapshots of your User Customized App or Website, or of your wedding invitations (if printed by us) to display examples of our work on our Site. We will ensure that any personal information does not make you identifiable. Otherwise we will ask for permission to publish to ensure that the couple feels comfortable with the information being disclosed.
7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
You have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
9. SHARING YOUR PERSONAL INFORMATION
Other than as provided herein, we do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may also share personal identification information to our commercial partners in the event that you elect voluntarily to process certain transactions through our Site or Service.
10. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
11. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data. by ensuring at least one of the following safeguards is in place:
– We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
– We may use specific contracts or codes of conduct which give personal data the same protection it has in Europe; or
– If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
12. THIRD PARTY WEBSITES
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
14. YOUR ACCEPTANCE OF THESE TERMS
By using the Site and/or App, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our Site or App. Your continued use of the App and/or Site following the posting of changes to this policy will be deemed your acceptance of those changes.
15. CONTACTING US
Invitations & Co Ltd
49 Station Road
Polegate BN26 6EA, UK
16 October 2018