Privacy Policy
This privacy policy describes how we process and protect the personal data ('Data') collected when you use our platform.
The terms used in this document have the same meaning as in our terms of use.
We assume that you reasonably expect the use of the platform to require the processing of your personal data. If you do not agree, you are free to stop using the platform or to object to the processing of your personal data.
We never collect your personal data in secret. We never ask for more than is reasonably necessary for the respective purpose.
In this document you will find out:
What data we process, how and for what purposes we process your data,
When and how we may share your data,
How long your data is kept,
The safeguards we apply to keep your data secure,
Your rights regarding the processing of your data.
If you are under 16, or if the law of your country sets a lower age for your valid consent to the processing of your personal data, you must obtain the authorisation of your parents or guardian before providing personal data to the platform.
1 Definitions
Personal data (or data) means any information about you which, alone or combined with other elements of information, makes it possible for a person collecting and processing it to identify you as an individual. This may include not only information about the person, such as name, address, gender, racial or ethnic origin, and so on, but also technical information about the person's devices, such as MAC, IMEI, UDID and IDFA addresses, IP addresses, browser information, location information and system information.
Processing of information means any action carried out with your personal data, for example collection, recording, organisation, structuring, storage, use, disclosure by any means, and so on.
2 Our legal bases for processing
We will process your personal data only where we have legal bases such as:
The processing is based on the consent you give us;
The processing is necessary to enable you to use the platform in accordance with our terms of use;
We will inform you of the legal basis applied to the processing and of other relevant details before starting to process your personal data on a specific legal basis not listed above, unless we are unable to do so in accordance with our obligations under any applicable law.
3 What data we collect, how we process it and for what purposes
3.1 The data you provide to us
This happens when you submit information in the various sections or forms available on the platform, such as 'Contact us' or 'Sign up', or when you register your account as an experience creator or as an experience participant. If you submit this information, you give us your agreement to process it.
3.1.1 Data from your account
We process all the data obtained from your account in order to enable the platform to operate.
We collect your first name and surname, your email address and your password as data required for account registration and its subsequent maintenance. Without this data we will not be able to ensure the proper operation of the Platform.
We also use your account data to enable you to communicate with us through the platform or by email. After receiving communications from us, you have the option to refuse those communications in each message, with the exception of legal notices, or to change the platform usage settings.
3.1.2 Publishing information on the Platform
We collect the data you publish while logged in to the platform. This includes the information you fill in on our surveys or in the 'Contact us' form, information drawn from your comments, your messages, experience options, and so on.
You acknowledge that any information you share will be available to the other users of the platform, unless we indicate otherwise.
3.2 Automatic collection (cookies and similar web technologies)
When you use the platform, we may automatically receive information from your device and send it back to you in order to improve your interaction with the platform and ensure that it works properly.
We process this data on the basis of your explicit consent, which allows us to collect cookie identifiers.
We use this data to assess the performance of the platform, to personalise our platform in order to offer you a more tailored experience, and to draw your attention to information about the platform.
Please refer specifically to our cookie policy for further details on our use of cookies and similar technologies.
4 Who we share your data with
4.1 Access by our employees
We may share your personal data with our employees or our vetted contractors. For the purposes mentioned above, we may share your personal data with these persons. We secure this processing by taking the necessary security and organisational precautions for such sharing.
4.2 Third parties
We do not transfer your data to third parties in the strict sense of the term. Technically, the data you submit will be processed and stored on proven servers and using approved software such as the Amazon Web Services cloud computing platforms (AWS S3, EC2, RDS, Code Deploy, Systems Manager).
5 How long we keep your data
We keep your data for as long as your account is in use. If you are banned, or if you decide to delete your account or simply to stop using it, we will keep your data for a further 12 months in order to ensure that we hold the information needed in the event of a dispute between the platform and users, or between users.
We do not keep information that has been deleted by you.
As for the data collected for newsletters, we will keep it for as long as you are interested in receiving our emails. We consider you to be interested until you unsubscribe from the newsletters by clicking the corresponding link contained in each of our emails, or by applying the appropriate settings in your user account.
6 How we protect your data
We use data encryption to keep your data secure. We will also notify users and the relevant authorities of personal data breaches where there is a high risk to your rights as a data subject. We will likewise do our best to minimise such risks.
7 Your rights
You have various rights regarding your personal data, in particular the right:
to obtain confirmation that we process your personal data and to request a copy of the personal data we hold about you;
to request that we update the personal data we hold about you, or correct any data you consider inaccurate or incomplete;
to request that we delete the personal data we hold about you, or restrict the way we use that data;
to object to the processing of your personal data and to withdraw your consent (where consent is the legal basis for that processing);
to obtain your data in a form that can be read and used across different computing environments by machines and software (right to data portability).
We undertake to respond to any verified user regarding any question arising from this privacy policy or from the applicable data protection laws. We undertake to respond within a reasonable time, taking into account the possibility of extending the response time by up to 24 hours because of the complexity and number of requests. In any event, we will inform you of such an extension.
To exercise any of your rights, or if you have other questions about the use of your personal information, please contact us using the details set out below.
8 Changes to this privacy policy
We may amend or update this privacy policy from time to time, by updating the 'Last modified' date at the top of this privacy policy and adding the details in the 'Main changes' section below. Your continued use of this privacy policy will confirm your acceptance of it. If you do not agree with this document, you must stop using the platform.
9 Contacting us:
If you have any questions about the privacy policy, please contact us.
Email address: support@cawtar.org
