- Information We Collect
2(a) – Circumstances in which the Service Provider is a data controller
When your agents, employees or contractors (the “Agents”) of your company (the “Partner Business” or “Partner Businesses”) visit, register or use the Service, they may be asked to provide certain information including, but not limited to, details such as name, date of birth, mobile number and email address.
We may also collect information about their usage of the Service such as specific information about their devices when signing up for and using the Service, including, but not limited to, their device’s hardware model, operating system, web browser version, unique device identifiers and mobile network information.
When the Agents use the Service, we may collect and store certain data, including the fact that they are accessing the Service, how that access is taking place, the dates and times of such access, where they are accessing the Service and device event information like crashes, system activity and hardware settings.
In addition, we collect information regarding the agents, employees and contractors of the Service Provider.
In only these circumstances does the Service Provider act as a data controller of all that information and data (the “Agent Data”) and as such we are responsible for how the Agent Data is used.
2(b) – Circumstances in which the Service Provider is a data processor
We may also collect information about your customers, including but not limited to, the information communicated while interacting with Agents through the third-party applications listed in Appendix 1 (the “User Applications”).
In such circumstances, the Partner Business is the data controller and the Service Provider is the data processor of all such information and data (the “Consumer Data”), and as such the Partner Business exclusively controls how the Consumer Data is used.
- Use of Data
We use the Agent Data and Consumer Data (the “Data”) to enable us to provide the Service to you.
We also analyse the Data to help us administer, support, and improve the Service. We may use the Data to contact you to tell you about important changes or developments to the Service, or to obtain views on the effectiveness of the Service.
Where you have agreed, we may use the Data to let you know about other products and services which might be of interest to you. If you want to stop receiving information about other products and services, you can opt out at any time by contacting us email@example.com.
At all times, access to the Data by our own staff and third party intermediaries acting under our instructions or behalf, will be restricted to the bare minimum required for us to perform our business and provide the Service.
- International or Cross-Border Transfer of Data and Your Express Agreement
The transfer of the Data is necessary to process your registration and use of the Service, to provide updates and to respond to your inquiries. Your location may result in the transmission of the Data by the Service Provider on an international or cross-border basis. By signing up for the Service or by using the Service and / or by communicating with us, you acknowledge and expressly agree and consent to our processing and disclosure of the Data in this way.
- Disclosure to Other People
We will never sell the Data to a third party for marketing purposes or otherwise.
We may pass the Data to our third party vendors and hosting partners to provide the necessary hardware, software, networking, storage and other technology and services required to operate and maintain the Service, which may require the Data to be shared. Although we own the software, codes, databases and all rights to the Service, you retain all rights to the Data.
The Data may also be shared with our third party intermediaries who provide customer support. These third party intermediaries are not authorised to use your data for any other purpose.
We may disclose the Data to courts and government agencies or bodies if requested to do so under a court order or legal process, or to establish or exercise our legal rights or defend against legal claims. In addition to that, we may also share the Data if we believe it is necessary to the investigation, prevention or the taking of an action regarding illegal activities, suspected fraud, the prevention of threats to the physical integrity of any person, violation of our terms and conditions, or as otherwise required by the law.
- IP Addresses
An IP address is a number that is assigned to your device automatically when you use the internet. When you visit a particular web page through the Service, our servers log your IP address.
We may use your Agent’s IP address to help diagnose problems with our server, and to administer the Service. Your Agent’s IP address is also used to help identify the Agent and the Partner Business and to gather broad demographic information.
Cookies are small pieces of information, stored in simple text files, placed on your device by a website. Cookies can be read by the website on your subsequent visits so that you can access information faster and in a more efficient way. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that you are “remembered” on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have separately furnished such information.
You can at any time set your browser to reject cookies. However, if you reject our session cookies, this may affect your ability to use the Service.
We use “session” cookies and “performance” cookies.
“Session” cookies help users to navigate across the Website’s pages. They are deleted once you leave the Service. Session cookies do not contain anything other than a session identification number which allows the webserver to “remember” where you are online. Session cookies are especially important for using the Service. Some examples of these cookies include:
- identifying you as being signed in to the Service and keeping you logged in throughout your visit; and
- remembering the content of forms which you may have completed while you are on the Service.
Performance cookies are used by us to provide information on the usage of the Service (details in relation to which pages users visited, how they got there, etc.). Some of these cookies are saved to your device so that we know when you revisit the Service. All information these cookies collect are aggregated and used anonymously. We use these cookies to understand what content is popular which helps us to improve the Service.
- Links to third party websites
We employ reasonable security measures to protect the Data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. The Data will be hosted on the cloud by Microsoft Azure at their Dublin facility or by any other cloud services provider with similar high technical and physical security.
We accept no liability whatsoever with respect to third party service providers.
- Data Retention
We will retain the Data for a reasonable period as set out in our Data Retention Policy or as specified by the Partner Business where appropriate and applicable or for as long as the law requires.
- Changing Your Information
You and your Agents are entitled to see the Data we hold about that particular Agent. The law entitles the Service Provider to charge you a fee of €6.35 to give you access to this information. If you wish to see this information, please contact us at firstname.lastname@example.org and forward a cheque in the sum of €6.35.
You and your Agents can also ask us to amend or delete the information we hold about that particular Agent to ensure that it is accurate and kept up to date. Please contact us at email@example.com to do so.
The Partner Business is also entitled to see, amend or delete the Consumer Data. As the Service Provider is not the data controller of the Consumer Data, the Service Provider will amend and / or delete Consumer Data as instructed by the Partner Business by email to firstname.lastname@example.org, subject to applicable law.
- Terms and Conditions
Appendix 1 – User Applications and Terms
User Applications includes, but is not limited to, the following applications, websites and other relevant properties, via which Users send messages to You and You can respond using the Site, through Our integrations with such applications.
- User Applications
“Facebook Applications” means the Facebook owned applications known as Facebook Website, Facebook Messenger Apps and Messenger Website.
“Twitter Applications” means the Twitter owned applications known as Twitter Website and Twitter Apps.
- User Applications Privacy Policieis
“Facebook Data Policy” means the Facebook Data Policy (found here: https://www.facebook.com/full_data_use_policy).
“Twitter Terms” means the Twitter Terms of Service (found here: https://twitter.com/privacy?lang=en).
- User Application Terms
“Facebook Terms” means the Facebook Statement of Rights and Responsibilities (found here: https://www.facebook.com/terms) and Facebook Platform Policies (found here: https://developers.facebook.com/policy/).
“Twitter Terms” means the Twitter Terms of Service (found here: https://twitter.com/tos?lang=en) and Twitter Development Agreement and Policy (found here: https://dev.twitter.com/overview/terms/agreement-and-policy).
Where “Facebook” means Facebook, Inc., a corporation headquartered at 1601 Willow Road, Menlo Park, CA 94025, USA and;
“Twitter” means Twitter, Inc., a corporation headquartered at 1355 Market Street
Suite 900, San Francisco, CA 94103, USA