This Data Policy describes in detail what information we collect from you, on what basis we collect it, how we use it, and rights you have to control how we use it. This policy takes effect on October 15 2021.
This policy applies to anyone who uses our website, https://plesion.com (the "Site") and our app (the "Mobile App"). We'll refer to the Site and the Mobile App together as "the App".
"We", Plesion, Inc. ("PLESION"), a company incorporated in Delaware, are the data controller as defined by the European Union's General Data Protection Regulation.
What information do we collect and why?
There are three categories of information we collect: (1) information you provide, (2) information created when you use the App, and (3) information from other sources.
1. Information you provide
When you use our App, you might provide us with personal information, favorite locations, content you post on the App, and direct communications.
Personal information
When you sign up for the Mobile App, you provide us with your name, username, email address and profile photo, which we use to ensure your saved places and other personalisation features are synced across your multiple devices. When you log in using Facebook, Google or Twitter, we do not send them any data about you, and we do not collect any information from them.
Favorite locations
You may choose to provide us with your favorite locations. We process this information in order to provide you with a personalized news feed.
Content you post on the App
If you want to communicate with people around you and share local information, you might post it on the App.
Direct Communications
Communications you might send to us include responses to in-App survey questions, reporting a problem, or submitting queries, concerns or comments regarding the App. These messages to us will also contain details such as the type of phone you're using, your service provider, and if you've enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We process this information in order to fix problems in the App, to reply to your communications, and to help keep you safe.
2. Information created when you use our App
The following are the types of information created when you use our App. We associate this information with a user ID number that is randomly generated when you create an account on the Mobile App. We use this user ID number to pseudonymise the data we collect from you, and do not access any permanent device ID numbers.
Location Information
When using the App, we ask that you enable access to your device's location as determined through data such as GPS, mobile phone towers, and WiFi. We use your location information to provide a location-specific news feed and map view.
Device Information
We collect information about the device you're using to access our App, including the type and model of device, its operating system and version, the preferred language, time zone setting, and device motion information. This information is necessary for us to diagnose bugs and improve the App.
Log and Usage Information
Each time you interact with our App, we collect information about how and when you use it, such as the time and date when you opened the App, the browser or app version you used (and its settings), the searches you make, the features you click on, pages visited, app crashes and other system activity. We use this information to improve our App in multiple ways. For example, using App crash data, we can fix bugs and prevent future crashes, and by knowing what gets tapped or scrolled most often, we can replace unpopular features with other, more helpful features.
Cookies
The App uses cookies to store certain information. Cookies are small pieces of information that a website or app transfers to your hard drive or mobile device to store and sometimes track information about your use of the site or app. Although they identify a user's device, cookies do not reveal the name, email address or other obvious identifiers of users.
When you interact with the App, we try to make that experience simple and meaningful. When you visit our App, our server sends a cookie to your computer or mobile device, depending on how you access the site or App. A number of cookies we use last only for the duration of your web session and expire when you close your App. These are known as "session cookies". Other cookies are used to remember you when you return to the App and will last for longer. These are known as "persistent cookies".
We use cookies to:
• remember that you have visited us before, which allows us to identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get; customise elements of the layout and/or content of the pages of the App; and
• collect information about how you use the App so that we can improve the App and learn which parts of the App are most popular to visitors.
Some of the cookies used by our App are set by us, and some are set by the third-party analytics and crash/error-reporting companies we've described in this policy who are acting on our instructions.
Most browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers. By blocking or deleting cookies you may not be able to take full advantage of the App's features.
3. Information from Other Sources
If you log into your PLESION account using Facebook, Twitter or Google, those companies provide us with your name and email address, which are necessary for us to log you in to the App. We do not collect or use any other information received from those two companies.
How we use your information, summarized
In summary, we use the information we collect to:
• Provide, operate and improve our App;
• Personalise your experience of the App and provide you with relevant information; e.g. highlight popular posts in an area and tailor the newsfeed we deliver to you based on your current location and saved places.
• Administer your account;
• Respond to your emails to discuss your use of the App, and answer any support queries you may have;
• Send you marketing communications by email or in-App notifications, and let you know about our policies and terms;
• Identify issues with the operation of the App, provide crash reports in order to find resolution for performance issues, monitor usage and resource needs;
• Improve the design, functionality and/or content of the pages of the App and customise them for you; and
• Disclose to lawful authorities when required to do so by law, or when appropriate, in our opinion, to respond to their request.
We work hard to improve the App and add functionality, which we think will make it safer and more useful for our users. New functionality may involve similar or incidental uses of your data to those set out above. We regularly review the way we use data, and will update our privacy policy to reflect these improvements to the App.
What third parties receive your information?
The App is a public platform. To that end, your name, username and profile photo as well as the content you post on the App, such as posts and replies, are visible to anyone accessing our App.
To the extent we share information with third parties, we do so to enhance your experience with the App, and we pseudonymise and minimize the data we send to them. These vendors and service providers are contractually required to use it only to provide their service to us, and contractually barred from using it for their own purposes.
• We have API Partners like Google and Apple in order for the App to send you addresses of the locations you want to follow. They receive the coordinates of the location you want to follow, and return a suggested address with a street name and city name.
• We use Analytics Vendors like Google Analytics to understand what you've tapped or clicked on the App, and we make functionality and design improvements based on this information. They receive information showing only that a person has tapped or used certain features in the App.
• We use Performance Testing Vendors to help test and analyze the performance of our website and mobile applications and Crash/Error Reporting Vendors to report on crashes you experience with the App so we can fix those, and to report on errors with our backend.
• Social media and Messaging Apps: If you choose to use certain sharing features in our App, then you may be sharing your information with those social media and messaging Apps companies, depending on factors such as that company's encryption policies.
• We use Communication Platforms to send you emails and updates about our services.
In using our App, you may come across links to websites and services operated by third parties (for example, if a user shares a link to a video on YouTube or a link to a post on Twitter). These third parties have their own privacy policies, which will apply to your activity if you click on the link and access their website or service. We do not accept any responsibility or liability for such external sites' privacy and security practices.
What is our legal basis for processing your information?
We'll only process your personal information where we have a legal basis for doing so. Our legal basis to process your personal data includes processing that is:
• necessary for our legitimate interests, which are:
⚬ to research, develop, fix and provide new and tailored features for our App users;
⚬ to provide our products and services which consist in allowing users to contribute and be aware of localized content;
⚬ to ensure that the App is secure for users;
⚬ to enforce and prevent breaches of our terms and policies, to protect our rights and property or to prevent harmful or illegal activity;
• necessary to comply with relevant legal requirements (for example, to comply with applicable regulatory obligations and to make mandatory disclosures to law enforcement); and
• based on your consent (for example, where you provide us with marketing consents), which may be withdrawn at any time by contacting us at the email address specified below.
What are your rights in relation to personal data we hold about you?
Access
Data Subject Access Request. You have a legal right under the GDPR to request access to a copy of the personal information about you held by us. In order to do this, contact us at support@plesion.com. Please use the subject line "DSAR" and include details about what personal information you're looking for. You will need to have created an account in order for us to provide you with your information because without an account, we are not able to connect your user ID to a verifiable email address.
Deletion
Subject to any legal obligations to keep your information longer, we store your personal information for as long as is necessary to provide our services and products, or until you ask us to delete it, whichever comes first. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims. We may retain your verification-related information for a reasonable period of time (even if you do not complete all verification steps) to assist with future verifications and to prevent abuse of our verification processes.
If you ask us to delete your personal information by emailing us at support@plesion.com, please use the subject line "Account Deletion."
Note that residual copies may take longer to be removed from our backup systems. We will keep a record of your request in order to ensure compliance with legal obligations.
Marketing opt-out
You have the right at any time to prevent the use of your personal information for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to us at support@plesion.com or clicking on the unsubscribe button at the bottom of marketing emails, and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes. Also, we may still send you non-promotional messages, or information about your account.
Notifications
We may send you information we think you may find useful or which you have requested from us by push notification and/or by email, and we or your device's operating system will give you the option to opt-out of receiving further notifications or emails.
How we keep your information secure
We place great importance on the security of all information associated with our users. We use measures such as encryption, pseudonymisation, information access controls, and firewalls to keep your data secure.
Keep in mind that submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk. Please ensure that you keep your password safe and do not share it with anyone.
What countries will your personal information be sent to?
Information that you submit via the App is sent to and stored on secure servers located in the European Economic Area countries and in the United States. Information submitted by you may be transferred by us to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (for instance in the United States).
We may rely on the EU-US Privacy Shield where we transfer your information to the United States, such as to certain of our third party service providers, where such recipients are certified to receive your information under the Privacy Shield Program.
By continuing to use the App, you understand that we may transfer and store your data outside your home country, including to and in the US, as described in this Data Policy. The privacy protections and the rights of authorities to access your personal information in some of these countries may not be the same as in your home country. We will only transfer personal data as permitted by law, and will take steps intended to ensure appropriate protection of your personal information.
Do we collect children’s information?
We do not knowingly collect personal information from children under the age of 13. If you're under the age of 13, please do not submit any personal information through the App or email. We encourage parents and legal guardians to monitor their children's internet use and to help enforce our privacy policy by instructing their children never to provide personal information on the App without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us as specified below, and we will work to delete that information from our databases.
How will you know about changes to our Data Policy?
We may revise this Data Policy from time to time. Any changes and additions to this Data Policy will be posted in the App and are effective from the date on which they are posted. Please review this Data Policy from time to time to check whether we have made any changes to the way in which we use your personal data.
What if you have a complaint?
We work hard to handle your information responsibly. If you're unhappy about the way we do this, please contact our Data Protection Officer by email to support@plesion.com.
How to get in touch with us
Please submit any questions, concerns or comments you have about this Data Policy or any requests concerning your personal data by email to our Data Protection Officer at support@plesion.com.
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