PRIVACY AND DATA POLICY
ISSUED BY MONTEROSA PRODUCTIONS LIMITED
Last Updated: 25 May 2018
1. INTRODUCTION AND GENERAL TERMS
These terms apply to the use of apps and other products developed by MONTEROSA PRODUCTIONS LIMITED (‘MONTEROSA’ / ‘we’ / ‘us’). Our registered office is at 5-9 Hatton Wall, London, England, EC1N 8HX. We are a company registered in England, with company number 04716325.
What information we may collect about you;
How we will use information we collect about you;
Whether we will disclose your details to anyone else; and
Your choices and rights regarding the personal information you have provided to us.
The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information used to operate Apps
In order to operate Apps, and offer their features, we collect and process the following information relating to each user:
For Competitions or Sweepstakes:
a “UUID”, which is a reference to a specific user, but which does not reveal their identity;
the user’s competition entry;
a competition submission ID; and
user’s mobile phone number; and
a certification of status as a genuine and eligible voter, based on a mobile phone number verified by SMS.
name, to be displayed on the leaderboard;
user demographic, if provided by the user, for example:
general location; and
IP address; and
Amazon SNS push notification token.
For Video Maker functionality via our chatbot:
Facebook profile picture; and
any personal data appearing in the video created by the User.
Information collected for the purposes of ecommerce
In order to fulfil your orders to our ecommerce stores, we collect and process the following information relating to each buyer:
Information used for personalisation, including:
other information used to personalise products;
Delivery name; and
Information collected for the purposes of providing analytics
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:
cookies, which reveal, amongst other things,
how many times you visit the Website;
which pages you go to;
Website traffic data;
social media ‘likes’ or social media enabled expressions of emotion in respect of viewed content.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide the Online Services to you
We will use eCommerce Data in order to fulfil your orders in accordance with the terms of sale agreed between us in respect of any products or services you buy.
To help us improve the Online Services and fix any problems
We may process Analytics so that we can analyse and improve our Apps and Online Services.
This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online Services function properly so that you and other users have the best experience when using any of them; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Online Services.
Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Website.
5. DATA SHARING
Publishers of any of our Apps: We may share your information with the publisher of any of our Apps that you install. This may be provided in aggregated form, or in a form which relates to you specifically. Please bear in mind that Apps are published on terms and conditions, and with privacy policies, issued by third party publishers.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of MONTEROSA, our customers, or others.
6. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let us know by sending an email to [ ].
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
you consented to our processing the personal data, and have withdrawn that consent;
we no longer need to process that personal data for the reason it was collected;
we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of MONTEROSA or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed;
you need the personal data to be deleted in order to comply with legal obligations;
the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
If you are unhappy with the way we are processing your personal data, please let us know by email to firstname.lastname@example.org
If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
7. DATA RETENTION
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as MONTEROSA management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. INTERNATIONAL DATA TRANSFERS
It is possible that your personal information may be transferred outside of the EEA by third parties referred to in the policies as being the recipients of your data. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.
Our servers are hosted by Amazon Web Services and Google Cloud Services.
Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to email@example.com
All questions, comments or enquiries should be directed to MONTEROSA at 5-9 Hatton Wall, London EC1N 8HX. We will endeavour to respond to any query or questions within three business days.
© 2018 MONTEROSA PRODUCTIONS LIMITED. All trade marks are the property of the relevant owners. All rights reserved.