Monterosa / Privacy Policy

PRIVACY AND DATA POLICY

ISSUED BY MONTEROSA PRODUCTIONS LIMITED

Last Updated: June 2020
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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 17 Mann Island, Liverpool Waterfront, England, L3 1BP. We are a company registered in England, with company number 04716325.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all apps and other software and products made available by us (together the "App(s)"), as well as our website (www.monterosa.co) and any of our ecommerce stores (the “Website”). Together the App(s), and the Website are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at support@monterosa.co

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

The publishers of our Apps control some of the data set out in this Privacy Policy jointly with us.

Please read this Privacy Policy carefully as it contains important information about the following:

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.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use for the Website and end user licence agreements and privacy policies of the Publishers of each of the Apps.

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.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Website.

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(“App Data”)

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;
IP address;
the user’s competition entry;
a competition submission ID; and
name

For Voting:

a UUID;
IP address;
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.

For Leaderboards:

a UUID;
IP address;
performance score;
name, to be displayed on the leaderboard;
Facebook ID;
user demographic, if provided by the user, for example:
gender;
general location; and
age bracket.

For Notifications:

a UUID;
IP address; and
Amazon SNS push notification token.

For Video Maker functionality via our chatbot:

a UUID;
IP address;
name;
Facebook profile picture; and
any personal data appearing in the video created by the User.

Information collected for the purposes of ecommerce

(“eCommerce Data”)

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:
name; and
other information used to personalise products;
Delivery name; and
Delivery address;
Phone number

Information collected for the purposes of providing analytics

(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. Please also see the cookies section below for more information.

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;
a UUID;
IP address;
content viewed;
social media ‘likes’ or social media enabled expressions of emotion in respect of viewed content.

Information you submit when you contact us through the Website, including through the chat functionality. This may include information about you, such as your name, your organisation, your email address, your organisation’s address and your enquiry.

(“Correspondence”)

3. WHY WE COLLECT INFORMATION ABOUT YOU

To provide the Online Services to you.

We will use App Data to deliver Apps to you under the terms of use agreed between you and the App publisher. The processing of information in this way is necessary for us to ensure the Apps deliver the features promised and function properly, so that you have the best experience when using the Online Services.
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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.

To respond to your Enquiries

We may process Correspondence to reply to your enquiries and provide you with information about the services we offer, including through the chat functionality on the Website. We do this in line with the legitimate interest we have in promoting and operating our business.

To conduct Online Marketing

We may process data (including Analytics) for online marketing, including remarketing, which allows us to show ads to people on third party services (including LinkedIn and Facebook), who've previously visited our Website.

We undertake this processing based on your consent. You can provide for marketing cookies and purposes, by clicking on and interacting with the cookie consent icon on the Website.

We work with social media platforms (including LinkedIn and Facebook). If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies. Links to these can be found in the cookie section below.

4. COOKIES

A cookie is a text file placed onto your device when you access our Website, as further detailed below. We use cookies and other online tracking devices such as web beacons, and flash object storage to help us understand how you use our Website, and how often, so we can improve them to deliver a better experience for our user. We also use cookies to carry out research and statistical analysis to help improve our content, products and services.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

Our Website should display a notice alerting you to our use of cookies and other similar technologies and linking to this privacy policy. If you click “I accept” or use our Website after this notice has been displayed to you we will assume that you consent to our use of cookies or similar technologies for the purposes described in this privacy policy.

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.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

5 DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy.

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.

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it 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), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

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.

Online Marketing: As set out in the cookie section above.

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 support@monterosa.co.

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 support@monterosa.co
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 hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

8. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at support@monterosa.co

9. SECURITY

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 support@monterosa.co

11. CONTACT INFORMATION

All questions, comments or enquiries should be directed to 17 Mann Island, Liverpool Waterfront, England, L3 1BP. We will endeavour to respond to any query or questions within three business days.

© 2020 MONTEROSA PRODUCTIONS LIMITED.
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