Effective of 25th May 2018
Thank you for choosing to be part of our community at GirlCrew (“company”, “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 policy, or our practices with regards to your personal information, please contact us at: firstname.lastname@example.org.
Table of contents
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
- WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, email address, date of birth, profile photo, password and social media login data, as well as messages, posts, likes, comments, and events you create.
We collect personal information that you voluntarily provide to us when [registering at the Sites or Apps,] expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites (such as posting in our city or topic groups or entering competitions) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information we COLLECT can include the following:
Name, Date of Birth, Gender and Contact Data. We collect your first and last name, your date of birth, gender and email address.
Credentials. We collect your password for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases such as GirlCrew Premium or GirlCrew Pro. All payment data is stored by our payment processors (Stripe and PayPal) and you should review their privacy policies and contact the payment processors directly to respond to your questions.
Social Media Login Data. We provide you with the option to register using Facebook account. If you choose to register in this way, we will collect the Information described in the section called “Social Logins” below.
Other Data. Data that you voluntarily give to us when choosing to participate in various activities related to the Site/Application, such as uploading a profile photo, chat, posting and commenting in our groups, liking posts, events or comments, sending feedback or enquiries, and responding to surveys. If you choose to share data about yourself via your profile or other interactive areas of the Site/App, please be advised that all data your and your data will be accessible to anyone who accesses the App.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.
We automatically collect certain information when you visit, use or navigate the Sites. 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 Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. [You can find out more about this in our Cookies Policy.
Information collected through our Sites and Apps
In Short: We may collect information regarding your mobile device, push notifications, and Facebook permissions when you use our apps.
If you use our Apps, we may also collect the following information:
- 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.
- Facebook Permissions. If you choose to sign up via Facebook, we by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
HOW DO WE USE YOUR INFORMATION?
In Short: We 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 Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). 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 login process [with your Consent]. If you choose to link your account with us to a third party account (such as your Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and login process. See the section below headed “Social Logins” for further information.
- To send you marketing and promotional communications [for Business Purposes and/or with your Consent]. We may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “Your Privacy Rights” below).
- To send administrative information to you [for Business Purposes, Legal Reasons and/or possibly Contractual]. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Fulfill and manage your purchases [for Contractual reasons]. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
- To post testimonials [with your Consent]. We post testimonials on our Sites that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
- Administer prize draws and competitions [for our Business Purposes and/or with your Consent]. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
- Request Feedback [for our Business Purposes and/or with your Consent]. We may use your information to request feedback and to contact you about your use of our Sites.
- To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
- To enable user-to-user communications [with your consent]. We may use your information in order to enable user-to-user communications with each user’s consent.
- To enforce our terms, conditions and policies [for Business Purposes, Legal Reasons and/or possibly Contractual].
- To respond to legal requests and prevent harm [for Legal Reasons]. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- 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 Sites, products, services, marketing and your experience.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
- Compliance with Laws. 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 and Legal Rights. 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.
- 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 Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyse 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.
- With your Consent. We may disclose your personal information for any other purpose with your consent.
- Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site [or App], such personal information may be viewed by all users and may be publicly distributed outside the Site [and our App] in perpetuity.
To make this site work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
TYPES OF COOKIES
The following types of cookies may be used when you visit the Site:
Analytics cookies monitor how users reached the Site, and how they interact with and move around once on the Site. These cookies let us know what features on the Site are working the best and what features on the Site can be improved. GirlCrew uses Google analytics cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works. These cookies collect information in an anonymous form.
Our cookies are “first-party cookies” and can be either permanent or temporary. These are necessary cookies, without which the Site won’t work properly or be able to provide certain features and functionalities. Some of these may be manually disabled in your browser but may affect the functionality of the Site.
Personalisation cookies are used to recognise repeat visitors to the Site. We use these cookies to record your browsing history, the pages you have visited, and your settings and preferences each time you visit the Site.
Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorised parties.
Site Management Cookies
Site management cookies are used to maintain your identity or session on the Site so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.
Advertising/Marketing cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Site and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you. We use Facebook cookies to register impressions on pages with the Facebook login button. We also have cookies used by Facebook to deliver a series of advertisemen t produ cts su ch as real time biddin g from third party advertisers.
CONTROL OF COOKIES
You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites offers you the ability to register and login using your third party social media account details (like your Facebook login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. [If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.]
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our app/desktop platform servers are located in Ireland. If you are accessing our app/desktop platform from outside Ireland, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information.
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognised by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
- Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
- For transfers to third parties in the United States, ensuring they participate in the EU-US Privacy Shield Framework.
7. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We may share information with third parties in order to provide our service.
We require a number of third parties to deliver our service. Without these, we cannot provide you with a service. For every third party service that we use, we have a Data Processing Agreement with that service provider and check that processing complies with the related legislation. The third party services we use include all the companies and services listed:
|Name||Service||Data Controller/ Data Processor||Description||Privacy URL|
|Amazon||Amazon Web Services (AWS)||Data Processor||Cloud based hosting and services||https://aws.amazon.com/privacy/|
|Filestack||Filestack||Data Processor||File uploading API||https://www.filestack.com/privacy|
|Google Analytics||Data Processor||User analytics tracking||https://policies.google.com/privacy|
|G Suite||Data Processor||Productivity and collaborations tools||https://policies.google.com/privacy|
|New Relic||New Relic||Data Processor||Application and server analytics and reporting||https://newrelic.com/termsandconditions/privacy|
|One Signal||One Signal||Data Processor||Notifications service||https://onesignal.com/privacy_policy|
|Stripe||Stripe||Data Controller and Processor||Online payment processing||https://stripe.com/ie/privacy|
|WP Engine||WP Engine||Data Processor||WordPress Hosting||https://wpengine.com/legal/privacy/|
HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise 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.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organisational 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 Sites is at your own risk. You should only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will delete 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 18, please contact us at firstname.lastname@example.org.
WHAT ARE YOUR PRIVACY RIGHTS?
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 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.
You have the right to access the data we hold on you. Subject access requests must be made in writing and include a copy of identification (such as driver licence or passport, this is to make sure that your personal information is not given to the wrong person) and must be addressed to the Data Protection Officer (see below). All access requests will be processed within one month on receipt of the access request.
You may at any time review or change the information in your account or terminate your account by:
- Logging into your account and updating your profile
- Contacting us using the contact information provided below
Upon your request to terminate your account, we will delete your account and information from our active databases.
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. You can also opt-out by contacting us at email@example.com.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, email us at firstname.lastname@example.org (subject “FAO DPO”) or by post to:
Data Protection Officer,
3 Guinness Enterprise Centre,