Before we get to the language that only attorneys can get a kick out of
reading, here is the nuts and bolts of how we ensure your privacy and just as importantly, our
core beliefs on security and your data.
Now the next part will get a bit technical, but there is no other way to explain the care we have taken to ensure your data is protected to the highest level of security. This language is not meant to sound complex so you gloss over it, it is meant to fully explain the care we take for those who understand technology so that we can stand behind what we have built to anyone, technical or non-technical.
Our system design uses "federated" architecture that ensures that there is no way for users outside of your chat group to see what you are sharing in that group. Your chat group members cannot forward your messages, you cannot accidentally post something to the wrong group, and content cannot spread beyond its intended audience.
Anything you share in Chatspace is encrypted in transit with SSL/TLS, then stored encrypted on secure servers by our hosting provider in the US. Chatspace uses the most advanced encryption security, physically separated data storage and two-factor authentication to ensure your messages are safe with no effort on your part. The data is encrypted in transit, and it is stored on encrypted disks on the servers. All data is automatically encrypted before it is written to disk. Each object's data and metadata are encrypted under the 256-bit Advanced Encryption Standard, and each encryption key is itself encrypted with a regularly rotated set of master keys. Our Cloud and Microservices architecture are highly secure and is the best in class security cloud architecture.
Now onto the legal language.
Thank you for choosing to be part of our community at Chatspace, Inc., doing business as Chatspace (“Chatspace”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our notice, or our practices with regards to your personal information, please contact us at email@example.com.
When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Apps and our services.
This privacy notice applies to all information collected through our mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy notice as the "Services").
Please read this privacy notice carefully as it will help you make informed decisions about sharing your personal information with us.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM MINORS?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS POLICY?
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps. We automatically collect certain information when you visit, use or navigate the Apps in order to service the features you rely on in the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.
IInformation collected through our Apps
In Short: We may collect information regarding your mobile device, push notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, contacts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Information automatically collected
In Short: SWe process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process.If you choose to link your account with us to a third-party account (such as your Google or Facebook account), which we currently do not support and plan not to support but may in the future, we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm.If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts.We may use your information for the purposes of managing our account and keeping it in working order.
To deliver services to the user.We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users.We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
For other Business Purposes.We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
In Short: We only share information with your consent, to
comply with laws, to provide you with services, to protect your rights, or to fulfill business
We may process or share data based on the following legal basis:
Consent:We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests:We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations:We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers.We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Other Users.When you share personal information or otherwise interact with public areas of the Apps, such personal information may be viewed by all users and may be publicly distributed outside the Apps in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Apps, and view your profile.
In Short: We keep your information for as long as necessary
to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through
a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.
In Short: We do not knowingly collect data from or market to
children under 13 years of age.
We do not knowingly solicit data from or market to children under 13 years of age. By using the Apps, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us at firstname.lastname@example.org.
In Short: In some regions, such as the European Economic
Area, you have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you have questions or comments about your privacy rights, you may email us at email@example.com.
If you would at any time like to review or change the information in your
account or terminate your account, you can:
Contact us using the contact information provided.
Opting out of email marketing:You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
Note your preferences when you register an account with the site.
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and collected. No
uniform technology standard for recognizing and implementing DNT signals has been finalized. As
such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in
a revised version of this privacy notice.
In Short: Yes, if you are a resident of California, you are
granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the mobile phone number associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
In Short: Yes, we will update this policy as necessary to
stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this policy, you may contact our Data
Protection Officer (DPO), Ed Han, by email at firstname.lastname@example.org, or by post to:
Ed Han 221, Main Street, Suite 148, Los Altos, CA 94023, United States