The following policy sets out how we collect, store, use and disseminate personal data relating to you and applies to all use of personal data by Second Screen Limited ("Second Screen", "we", "us" or "our") and branding partners of ours who use the Second Screen technology platform to reach fans like you, including the event organiser, artist or label that the app you are using is designed to promote.
Second Screen is committed to protecting and respecting your privacy. This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data you supply through these online services is processed, we (and where applicable our branding partners) are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 (“the Regulation”).
This policy explains the following:
Our online services contain hyperlinks to websites owned and operated by third parties. These third party websites may have their own privacy policies and we recommend you to review them. They will govern the use of personal information you submit or which are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of them is at your own risk.
If you have any concerns about your privacy, this policy or any websites or apps operated by us, please contact us at email@example.com
Second Screen apps and websites provide information about events and artists, and social networking services (together, the “Service”).
2. CHILDREN’S PRIVACY
2.2. If you are under the age of 13, you must not use the Service.
2.3. If a minor has provided us with personal information, this information may be deleted without further notice.
3. WHAT DATA DO WE COLLECT?
3.1. We may ask you for, or you may submit, personal and non-personal information and data to us when you use the Service. This could include:
· your browsing and log data collected by Google advertising cookies and other technical means that we may employ to recognise your device and the actions you take when you visit the Service (“Analytics”);
· your name, address, gender, age, location, home country and city, which may be collected from your Facebook profile, where you use Facebook to log into the Service and authorise our access to that information
· details of events you wish to, and do, attend;
· your username and password;
· your email address;
· your phone number; (collectively “Profile Information”);
· any content including photos and videos you submit to the Service ("Your Content”), such as comments.
3.3. When you get in contact with us we may keep records of what is communicated. This is to ensure we have a record of our discussion for future reference and so we can provide the Service to you more efficiently.
3.4. We might collect sensitive information about you, but we will never collect your sensitive information without your explicit consent.
4. USES OF DATA
4.1. We use data for the following purposes:
4.1.2 For the purpose of allowing users to make profiles: We will use your Profile Information to allow you to make profiles within the App to allow you to interact with other users. This processing is necessary for us to pursue our legitimate interests of ensuring that our Services function properly so that you and other users have the best experience when using our App(s) and for ensuring that profiles are linked to real people and fans of our Branded Partners.
4.1.4 For the purpose of Advertising: We may use age, gender and location data for the purpose of allowing third parties to run targeted advertising campaigns. This information is not shared with any third parties and is anonymised but processed so that third party advertisers can target advertising campaigns to chosen demographics of users of our Apps. This processing is necessary for us to pursue our legitimate interest of offering our Apps for free to users and to provide users with adverts that are relevant. You can opt out of this see section 6 below.
4.1.5 For the purpose of Direct Marketing: Where you have agreed to we and our branding partners might send you marketing emails about products or services which are similar to or related to those available via our online services. You can opt out of this Service (see section 6 below). If you would like to be removed from this please let us know.
4.1.6 For the purpose of Analytics: We may use Google and our own advertising cookies and anonymous identifiers: to conduct analytics on your visit to the Service, including by recording and analysing user behaviour, location, audience, demographic and interest data. This information may be used in order to enable the remarketing of users and may be shared with Google and other third party advertisers, but only on an aggregate and anonymous basis. This processing is necessary for us to pursue our legitimate interests of improving our services, and providing a better experience to our users.
4.2. Information submitted to or collected by the Service may also be used to:
· enable our compliance with applicable laws and regulations;
· enable our compliance with any agreements entered into between us;
· enable your use of the Service and associated services;
· understand how the Service is being used;
· provide you with an up to date, efficient and reliable Service; and
· generally run and improve the Service.
4.4. Be aware that some of Your Content may be made public, depending on how it is posted. We will not make public any information which is stated as being posted privately. However, not all means of posting are private. Please be careful when determining what of Your Content to submit and only submit Your Content if you are happy for it to be read by others. By default, all of Your Content will be published to other users of the Service.
5. DATA SHARING
5.1.2 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.
5.1.3 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).
5.1.4 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 Second Screen, our customers, or others. If you are using a part of the Service which is dedicated to a particular branding partner (such as a particular artist, label or event organiser) they will be able to access your Profile Information and any other information that you share with them.
6. CONSUMER CONTROL & OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us or third parties, or targeted ads or for your data to be processed for analytics purposes then you can contact us at the following email address: firstname.lastname@example.org.
7. MANAGEMENT OF DATA
7.1. We will only use information collected about you in accordance with the Regulation.
7.3. If you believe we have information about you that you do not want us to have or that you think is incorrect, please contact us.
7.4. Although we will do our best to protect your personal data from misuse, interference, loss and unauthorised disclosure, we cannot guarantee the security of data transmitted to the Service. Any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
7.5 You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest. To make a request, please let us know at email@example.com.
7.6 Ask for a copy of data we are processing about you and have inaccuracies corrected.
7.7 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).
7.8 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 Second Screen processing the personal data, and have withdrawn that consent;
· Second Screen no longer needs to process that personal data for the reason it was collected;
· Second Screen is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Second Screen, 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 a legal obligations;
· the personal data is processed in relation to the offer of a service to a child.
7.9 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, 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, Second Screen will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
7.10 Make a complaint to a Supervisory Authority
· If you are unhappy with the way Second Screen is processing your personal data, please let us know.
· 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 to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
8. COOKIES AND OTHER TRACKING TECHNOLOGY
8.1. We use ‘cookies’ and similar technologies on the Service. Cookies are small computer files which the Service may store and/or access in your internet browser, enabling information to be transmitted to and from your device and the Service. Cookies may also be stored in your internet browser by or on behalf of third parties, such as Google, LinkedIn, or providers of advertising services.
8.2. Cookies enable us to record anonymous information about you, including: the type of internet browser or device you use to access the Service, your device operating system, the websites you visited before visiting the Service, the areas of the Service you visit and your IP address (which can provide information about your approximate geographic location). Cookies cannot be used to disclose your individual identity.
· learn about how the Service is being used and which types of individual are using the Service;
· record and report user profile, behaviour, location, audience, demographic and interest data;
· record which other websites have referred users to the Service;
· optimise and improve the Service;
· make it easier for you to fill in forms on the Service and remember the information you have submitted to the form;
· enable the Service to remember your preferences;
· enable aspects of the Service to be customised; and
· provide relevant advertising.
8.6. If you want to learn about how to opt out of Google Analytics, please see visit https://tools.google.com/dlpage/gaoptout/ or your Google Ads Settings.
9. DATA RETENTION
We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected.
10. INTERNATIONAL DATA TRANSFERS
10.1 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 firstname.lastname@example.org.
11.1. If you follow a link from the Service to any third party apps or websites, for example to purchase a ticket for an event, you should be aware that those apps or websites may have their own privacy policies. We do not accept any responsibility or liability for those apps or websites. Please check the policies of any third party apps or websites before submitting any personal data to them.
11.3. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours. In accordance with applicable data protection law, you have a right to access, rectify and remove any of your data which are inaccurate, incomplete or outdated. You may exercise this right by contacting email@example.com or write to us at the address below. We reserve the right to charge a reasonable fee at our standard rate for any requests for copies of personal data held by us.
SECOND SCREEN LIMITED
Company Number 08946567
115b Drysdale Street
N1 6ND, UK
Updated 25 May 2018