Scope of Policy
This policy (together with our EULA) applies to the following:
Our browser based data analytics software applications, Emoticse and the Toneapi Text Analysis Tool (together the Software), each made available through adoreboard.com or such other sites as we may notify you from time to time (our Sites);
Your use of any services accessible through the Software or otherwise provided by us (Services); and
Any documents provided by us in connection with the Software (the Documents).
For the purpose of the GDPR/ DPA 2018, we are the data controller. We are registered with the Information Commissioner’s Office for the processing of personal data under registration number ZB057408.
Information we may collect from you
We may collect and process the following data about you:
Submitted Information: information that you provide by filling in forms or uploading data when using or interacting with the Software and the Services. This includes information provided at the time of registering to use the Software or any of the Services, subscribing to any of the Services, posting material, or requesting further Services, including, without limitation, your email address, name, company details (including your role) and personal comments. We may also ask you for information when/if you report a problem with the Software or the Services.
If you contact us, we may keep a record of that correspondence;
Any data submitted in relation to surveys you undertake in connection with your use of the Software and the Services; and
Details of transactions you carry out through our Software;
Authorisation and access to third party applications such as Google Analytics, Facebook Insights and data collected by these applications; and
Details of your visits to any of our Sites and use of our Software including, but not limited to, text that you upload, traffic data, location data, weblogs, search results and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access.
Technical Information: Each time you visit one of our Sites or use our Software we may automatically collect information about your device or computer, including where available details of the type of computer or device you use, a unique device identifier (for example, your device’s mobile number or IMEI number), your IP address, your operating system, the type of browser you use and time zone setting. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Third Party Information: We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies or software providers such as Gravatar®, Google® or Facebook®) and may receive information about you from them, including login details, profile pictures or other information.
IP Addresses and Cookies
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Software and to deliver a better and more personalised service.
We implement all Google Analytics Advertising Features information for purposes including, but not limited to re-marketing, demographics and interest reporting.
In particular, our Sites use Google Analytics to estimate our users’ usage patterns. Google Analytics counts the number of visitors and tells us things about their behaviour on our Sites, such as the typical length of stay on the site or the average number of pages a user views.
As part of the operation of Google Analytics, Google will take the information about your visits to our Sites and store the information on its sites in the USA. It is important to note that the USA is not included in the European Economic Area’s (EEA) list of countries recognised as having as stringent data protection regimes as EEA countries. Google will use the information it collects about you to understand your use of our Sites and Software, to compile reports on website activity and to provide other services relating to website activity and internet usage.
You can opt-out of Google Analytics for Display Advertising, to prevent your data from being used by Google Analytics, by going to the Google Analytics opt-out page.
We may use third party cookies to enhance your user experience. Such third party cookies will be governed by their own terms and privacy policies, so you should read these before giving your consent to enable these third party cookies.
Where we store your information
As noted above, the data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, including our hosting services provider. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services.
Where we have given you (or where you have chosen) a password that enables you to access the Software using our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Whilst we shall use reasonable commercial endeavours to store all information you provide to us safely and securely, unfortunately, the transmission of information via the internet, or storage of information digitally, is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us or our Sites or otherwise or the data transmitted when using the Services or the Software. Any transmission is at your own risk. Once we have received your information, we will use reasonable commercial procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your computer or other device using application data caches and browser web storage (including HTML 5) and other technology.
Certain Services include chat features, including the interactive chat facility offered by the Software. As you will be personally identifiable from your identification with these Services, please ensure when using same that you do not submit any personal data that you do not want to be seen, collected or used by us or our employees, agents or sub-contractors.
Uses made of your information
We use information we collect or hold about you in the following ways:
to carry out our obligations arising from any contracts entered into between you and us;
to allow you to participate in interactive features offered by the Software, where you choose to do so;
to contact you to check on your progress in your use of our services, and to discuss any subscription issues;
to ensure that content from our Software is presented in the most effective manner for you and for your computer or device;
to send you a newsletter or other marketing communication;
for the purposes of system administration and to report aggregate information to our advertisers;
to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; and
to notify you about changes to our service.
Please note that if you do withdraw your consent we may be unable to provide some or all of our services, and/or the use of Software or Services, to you, and you accept and acknowledge that we have no liability to you in any such event.
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, including with respect to requests regarding licensing of copyrighted content.
In order to:
enforce or apply the EULA, the Commercial Licence, and any other relevant agreements or to investigate potential breaches; or
protect our operation, rights, property or safety, that of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Software or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Access to Information
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act, and you can contact us at our registered address as given above or by emailing firstname.lastname@example.org. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
You also have the right to ensure that we hold correct and up to date information. If you believe that any information we hold about you is incorrect or out of date, please contact us at our email@example.com. We may need to ask you for further information and identification to help us to comply with this request.
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