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App Attic Privacy Policy

Last Updated: November 11th 2021

1. Definitions

AppAttic Ltd (“we,” “us,” and “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy, together with our Terms of Service and our Cookies Policy, describes how we collect and process your personal data when you access this Website (www.appattic.com), use any software, products or services, communicate with us by email, telephone or text-based messaging, or interact with any advertising we may run from time to time on third-party websites (together “the Services”).

It contains information as to how we treat your data when you engage with any of these Services, such as where you register for an account, purchase one of our software apps or product listings, subscribe to our newsletter, or take part in any competition or promotional campaign that we may run from time to time.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully as it contains information on the types of information we collect from you when you access, interact with or use our Services, how that information may be used by used or disclosed by us, and the safeguards we use to protect it.

2. Who We Are

AppAttic is a trading name of AppAttic LTD, a company incorporated and registered in England and Wales under company number 13045669, and with registered offices at Flat 22 Lawford Mews, 28 Waterloo Road, Bristol, BS2 0PN, England, United Kingdom of Great Britain and Northern Ireland.

AppAttic LTD is the data controller that is responsible for processing your information. A data controller is the legal entity that determines the purposes and manner for which personal data is processed.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as described below), please contact the DPO using the details set out below.

3. Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways.

Full name of legal entity: Ana-Maria Bunaiasu

Postal Address: Flat 22 Lawford Mews,28 Waterloo Road, Bristol, BS2 0PN, England, United Kingdom of Great Britain and Northern Ireland

Email: support@appattic.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

4. Changes To This Privacy Policy and Your Duty To Inform Us Of Changes

We may update this Privacy Policy from time to time. Where we do so we will update the “Last Updated” header at the top of the page, and include a bullet point summary of any material changes that have been made and how these affect you. Historic versions of this Privacy Policy can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

5. Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

6. The Data We May Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data)

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of our Services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

Profile Data includes your username and password, purchases and orders made by you, your interests, preferences (including direct marketing preferences), feedback and survey responses.

Usage Data includes information about how you use our Website and Services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

User-Generated Data includes any information that you might provide to any discussion forums on the Website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

7. If You Fail To Provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case.

8. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details. Examples of the data that is collected through such methods include:

(a) Service metadata. When a user interacts with the Services, such as where they click a link on the www.appattic.com website, metadata is generated that provides additional context about the way that users our engaging with our content. For example, AppAttic logs the features, content and links that you view or interact with, the types of product listings you view and the third-party links you click on (if any).

(b) Log data. As with most websites and technology service delivered over the Internet, our servers automatically collect information when you access or use the Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

(c) Device information. AppAttic collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this information often depends on the type of device used and its settings.

Single sign-on systems (“SSOs”). A single sign-on is a session and user authentication service that permits a user to use one set of log-in credentials – for example, a username and password- to access multiple applications. AppAttic allows you to use your existing Shopify account details as a single sign-on to register an account with us and use our services. Where you choose to use this option, we may receive equivalent data as to that which we would have received if you registered an account separately with us, including your name, username and password. Please note that, in compliance with the 2019 decision of the European Court of Justice in Fashion ID, which has been retained in UK case law after Brexit, we do not allow Facebook to use the SSO account token it grants you to operate any scripts on our Services.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) Analytics providers such as Google based outside the UK;

(b) social media platforms such as Facebook or Linkedin based both inside or outside the UK, when you use social login to sign into the www.appattic.com website using your social media platform account, or press any Facebook, Twitter, Instagram or Linkedin icon embdeed on a product listing featured on www.appattic.com such as where you “like” or “share” a featured product.

(c) service providers including Shopify (www.shopify.com) based outside the UK;

(d) advertising networks chosen from time to time based inside or outside the UK; and

(e) search information providers Google based outside the UK;

(f) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Square based outside the UK.

9. How Do We Use Your Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

10. Purposes For Which We Use Your Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity
(b) Contact
(c) Business Details
(d) Business Website

Performance of a contract with you

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Business Details
(g) Business Website

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Business Details
(f) Business Website

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Business Details
(h) Business Website

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical
(d) Business Details
(e) Business Website

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(g) Business details
(h) Business website

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(g) Business details
(h) Business website

Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, have opted in to receive direct marketing by ticking the marketing and communication consent box in your AppAttic account settings, or have previously purchased goods or services from us and have not subsequently indicated to us that you do not wish to receive further communications about related products or services.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of www.appattic.com may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Please note that this website is not intended for children and we do not knowingly collect data relating to children.

11. Disclosing Your Information

We may share your personal data with the parties set out below for the purposes set out in the table in clause 10 above.

Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.

12. Where We Store Your Data and Security

We may transfer your collected data to storage outside the UK. It may be processed outside the UK to fulfil your order and to receive our Services and deal with payment. If we do store or transfer data outside the UK, we will ensure that your data is treated as safely and securely as it would be within the UK and under the UK GDPR, and in all circumstances, in accordance with the judgment of the Court of Justice of the European Union (CJEU) in Case C-311/18 Data Protection Commissioner v Facebook Ireland and Maximilian Schrems (“Schrems II”).

Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements, including the Standard Contractual Clauses adopted by the European Data Protection Board under Articles 28(7) and 46(2)(c) of EU GDPR on 27 June 2021

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following two safeguards is implemented:

13. Data Security

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Data Retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

15. Your Legal Rights

When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy.

Under the UK GDPR, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at [Insert Address/Email Address].

16. Terms and Conditions

Please also visit our Terms and Conditions establishing the use, disclaimers, and limitations of liability governing the use of our Website.