Draft: 18 July 2021
Effectivedate: 18 July2021
1. Introduction and Application
(a) Itsmy.contact“Itsmycontact” “us”, “we”, or “our”), is committed to protecting your privacyand the security of your personal information.
(c) Byusing the Service, you agree to the collection and use of personal informationand other information in accordance with this policy.
User: a Paid Plan User or a Free PlanUser, or a Visitor.
Paid PlanUser: a personwho has signed up to a Paid Plan.
Free PlanUser: a personhow has signed up to a Free Plan.
Visitor: a visitor to the Website (i.e.the Itsmycontact marketing website).
End User:has themeaning give to it in the Terms of Service.
2. What personal information do we collect?
(a)Personal data means information or data about a living individual who can beidentified from that information or data (which includes information or data inour possession or which is likely to come into our possession).
(b) Wecollect several different types of personal information for various purposes.In the table below we have categorised this personal information and describewhat is it and how we may collect it.
(c) Typesof Data Collected:
This isthe personal information that is provided by you (ie a User) when you sign upfor and use the ItsMyContact Service.
If youhave a Free Plan: Suchpersonal information may include email address, name, username, hashedpassword, city/country when signing up, any country of last sign-in,Language/browser type, vertical (industry), application data (eg userpreference).
If youhave a Paid Plan: Suchpersonal information may include all of the information above, plus creditcard details (stored by Midtrans, not by us), and full name for billingdetails.
Inaddition to theabove, we may use and store information about Visitors. This isanonymised and aggregated in high quantities, and we remove any personalinformation as we are interested in the “how” not the “who”.
Thisincludes information on how the Itsmycontact Service is accessed and used by Users and EndUsers, as well as usernames and passwords, internet protocol (“IP”) addresses(and geographic information from an IP address), browser types, time zonesettings, the time spent on webpages, unique device identifiers and otherdiagnostic data.
We mayuse and store information about your approximate location (e.g. your country,city or postcode) using geographic information from your IP address. We usethis data to provide features of the Itsmycontact Service, and to improve and customisethe Itsmycontact Service.
Thisincludes your preferences in receiving marketing communications from us.
(d) Certainaspects of your personal information, for example user data, are required forthe Itsmycontact Services and if you fail to supply such information asrequested for specific Itsmycontact Services, we may be unable to provide youwith the products and services in full and your enjoyment of such products andservices may be more limited.
We do notcollect any sensitive personal information about you (this includes detailsabout your race or ethnic origin, political opinions or associations, religiousbeliefs or affiliations, philosophical beliefs, membership of a professional ortrade association or union, sexual orientation or practices, and criminalrecord information). Nor do we collect any information about your health,genetic background or biometric personal information.
3. Why do we collect your personal information?
(a) Itsmycontactuses the data we collect for various purposes, including for the most commonpurposes listed below:
4. How do we collect your personal information?
(a) Wewill collect personal information directly from you wherever it is reasonableand practical to do so. We may collect personal information from you via:
(b) Wemay also collect your personal information from third parties including:
(c) Thelegal basis for collecting and using personal information will depend on thespecific circumstances in which we collect that data. However we will collectpersonal information from you where:
5. Who we may disclose your personal informationto?
(a) Thirdparty disclosure
We maydisclose your personal information to various third parties. These thirdparties are likely to include:
(b) Inrelation to 5(a)(7) above, because we provide paid products and/or serviceswithin the Service, we use third party services for payment processing. We willnot store or collect your payment card details. That information is provideddirectly to our third party payment processors whose use of your personalinformation is governed by their privacy policies and their own terms andconditions. These payment processors adhere to the standards set by paymentcard industry data security standards (“PCI-DSS”) as managed by thePayment Card Industry Security Standards Council, which is a joint effort ofbrands like Visa, Mastercard, American Express and Discover. PCI-DSSrequirements help ensure the secure handling of payment information. Thepayment processors we work with are:
(c)Disclosure of personal information to other countries
(d) The ItsmycontactService may also use third party website tools from time to time, for exampledata analytics and online survey tools. These third parties have access to yourpersonal information only to perform these tasks on our behalf and areprohibited from disclosing or using it for any other purpose. These serviceproviders may change from time to time, but they generally include thefollowing:
(e) Yourweb browser can also be configured to reject cookies. If you set up your webbrowser to reject cookies certain functions of the Website may becomeunavailable to you.
7. Direct marketing communications
8. How long do we retain your personal information?
9. How do we secure your personal information?
(a) Wehave put in place appropriate security measures to prevent your personalinformation from being accidentally lost, used or accessed in an unauthorisedway, altered or disclosed.
(b) Inaddition we limit access to your personal information to employees, agents,contractors and other third parties who have a business need for access. Theywill only process your personal information on our instructions and they aresubject to a duty of confidentiality.
(c) Whilewe strive to use commercially acceptable means to protect your PersonalInformation, we cannot guarantee its absolute security. Therefore we have putin place procedures to deal with any suspected personal information breach andwill notify you and any applicable regulator of a breach where we are legallyrequired to do so.
10. Links to other sites
(c) Ifyou decide to access or interact with any of these third party websites, you doso at your own risk. As such, we strongly encourage you to review the privacypolicy of every website you visit.
11. What are your rights in relation to personalinformation?
(a)Access and correction of personal information
Subjectto certain limitations and restrictions (e.g. depending on circumstances suchas where you reside) you may have the right to exercise additional rights inrelation to your personal information. This may include the rights under theGeneral Data Protection Regulation (the “GDPR”). Accordingly, the followingrights might be available to you depending on your location and except aslimited under applicable law. These may include the right to:
1.Access, update or to delete the information we have on you
2. Theright of rectification
You havethe right to have your information rectified if that information is inaccurateor incomplete.
3. Theright to object
You havethe right to object to our processing of your personal information.
4. Theright of restriction
You havethe right to request that we temporarily or permanently restrict the processingof your personal information.
5. Theright to data portability
You havethe right to be provided with a copy of the information we have on you in astructured, machine-readable and commonly used format.
6. Theright not to be subject to automated decision making
You havethe right to not be subject to a decision based solely on automated decisionmaking, including profiling, where the decision would have a legal effect orproduce a significant effect on you.
7. Theright to withdraw consent
You alsohave the right to withdraw your consent at any time where we relied on yourconsent to process your personal information.
(c) Pleasenote that in order to verify your request or the applicability of any of theseright to your circumstances, we may ask you for further information and toverify your identity before responding to such requests.
(d) Ifyou have any questions about these privacy rights, or how to exercise them,please contact us using the contact details at the bottom of this PrivacyPolicy. You may also have the right to complain to your local data protectionauthority about our collection and use of your personal information.
(a) Wetake your privacy concerns seriously. If you have a complaint regarding ourhandling of your personal information or concerning our privacy practices, youmay file a complaint with us using the contact details set out at the ContactUs. We will confirm receipt of your complaint and, if we believe necessary, wewill open an investigation into your complaint.
(b) Wemay need to contact you to request further details of your complaint. If aninvestigation has been opened following a complaint made by you, then we willcontact you with the result of that complaint as soon as possible. In theunlikely circumstances we are unable to resolve your complaint to yoursatisfaction, you may contact the local privacy and data protection authoritiesin your jurisdiction.
14. Contact Us