Data Controller and Owner, Types of Data collected
The owner does not provide a list of Personal Data types collected.Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of Cookies - or of other tracking tools - by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
How We Collect Personal Data
What personal data we collect depends largely on the interaction that takes place between you and Talenthon, most of which can be categorized under the following:
- When you use Talenthon Service. When you use Talenthon
Service, we store all the
content you provide, including information related to you as a customer or an end user
of the Service. We gather
this information from you directly when you enter it, or from integrations that you
linked to the Service
(Facebook, Instagram, Whatsapp, Telegram, Stripe etc.). When you ask us to sign DPA or
other documents, we also
receive data about you and your representatives.
In some cases, we can receive information from third parties, e.g. from a payment serviceprovider on whether yourpayment was successful.
- When you send us emails or message us. When we receive emails or
messages from you in the
chat, we can store the content of such emails, attachments as well as your contact
details.
- When you submit forms on the Site or participate in our
events. When you complete forms on
the Site (contact us, subscription, demo request, event registration, etc.) we collect
your contact details and
information you complete in the form. If we arrange joint events together with our
partners, we can receive
information from our partners.
- When you use the Site. When you use the Site, we collect certain
information, as described
in more detail below that may, alone or in combination with other information,
constitute personal data (e.g.
cookie files).
- When you join our communities. When you join our Facebook and
other groups, we can see
data in your profile and process comments you posted in our groups. However, we don’t
gather that information or
copy it into our systems, but rather just have access to it.
What Types of Personal Data We Process
We collect and process the following personal data:
- Customer account details. To create or update your account and provide
the Service we collect
from you and third-party integrations (e.g. Facebook, Instagram, WhatsApp, Telegram)
information about you, as a
customer or end-user of the Service. This includes id, name, email, status, linked pages
and accounts, products
in use, location, etc.
- Financial information. To process your payments for the Service
subscription, we need your
credit card details (last four digits of the card number), account details and payment
information.
- Contact details and business data. We receive information about our
customers and potential
customers for cooperation and communication purposes. This includes full name, title,
company, email or other
contact details as may be necessary.
- Requests, messages and submitted forms details.
We receive and process
your messages, support requests, emails and information you share with us via online
forms or social media
accounts. This includes the content of such communications as well as your contact
details if any.
- Usage data, logs and other technical data. When you interact with the
Service, metadata and log
files are collected automatically. Log data may include the Internet Protocol (IP)
address, your browser type
and settings, the date and time you used the Service, information about browser
configuration plugins, language
preferences, the pages or features which you browsed, time spent on those pages or
features, the frequency of
pages and functions use, the links clicked on or used. If you use the Service from your
phone, this may also
include the type of device, operating system, device settings and device identifiers.
- Email performance data. To track engagement and performance metrics of
our newsletters, we can
use a ‘clear image’ (gif) in email communications. Much of this data is aggregated. If
you wish to turn off this
tracking, you can do so by turning off images in the email itself.
- Website cookies and similar technologies. We use cookie technology on
the Site.
- Customer Content. As you use our Service, you may import into our
system personal data you have
collected from your users, customers, prospective customers, social media and messaging
platform contacts
(collectively “Subscribers”) or other individuals. We process this data
only on your behalf as
our customer. We have no direct relationship with your Subscribers or any person other
than you, and for that
reason, you are responsible for making sure you have the appropriate permission and
legal basis for us to
collect and process information about those individuals. For information relating to how
we process personal
data relating to Subscribers, please see our Data Processing Addendum.
We ask that you not send or disclose to us any sensitive personal data (e.g., social security
numbers, information
related to racial or ethnic origin, political opinions, religion or other beliefs, health,
biometrics or genetic
characteristics, criminal background or union membership) on or through the Service or
otherwise.
For Which Purposes We Use Personal Data
We collect and process your personal data for the following purposes:
- To operate the Service: We use data to enter into the agreement with
you as a customer and
operate, maintain and administer your account in the Service, as well as to communicate
with you regarding the
account (sending announcements, technical notices, updates, security alerts, and support
and administrative
messages) and to respond to Service-related requests, questions and feedback. We also
use your data to perform
our billing obligations.
To provide the Service we process Customer Content information on your behalf as a customer (see details in Data Processing Addendum).
- To communicate with you and inform you about the Service. If you
request information from
us, register for the Service, complete a form or feedback on a Site, or participate in
our surveys, promotions
or events, we may send you Talenthon-related marketing communications if permitted
by law. In all such
communications, we will provide you with the possibility to opt-out.
- To conduct events and communicate with you. We use your personal data,
which you provided while
registering for the event, to send you reminders about the event, communications related
to the event and
Talenthon-related services. As well, we may ask for your feedback. In
communications, we always provide the
possibility to opt-out from communications.
- To comply with law. We use your personal data as necessary to
comply with applicable laws,
including sanction requirements, accounting and tax obligations, legal processes or
audits, to respond to
subpoenas or legally binding requests from government authorities. Before disclosing any
information to an
authority upon its request, we check the validity of such request carefully.
- To negotiate, enter and perform agreements. We have to collect and
process information
about our counterparties and their representatives to negotiate and enter into legally
valid agreements and
cooperate with them.
- For compliance and safety. We use your personal data as we believe
necessary or
appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect
our rights, privacy,
safety or property, and/or that of you or others; and (c) protect, investigate and deter
against fraudulent,
harmful, unauthorized, unethical or illegal activity.
How We Share Personal Data
We do not sell your data to third parties for commercial or advertising purposes. We share your data as described in this Privacy Policy or upon obtaining your consent for such data sharing.
We disclose personal data to third parties under the following circumstances:
- Service Providers. We employ third-party companies and individuals
to help us with
performance of certain activities, e.g. payment service providers. We also use
third-party software to process
data (e.g. CRM, email agent, cloud storage solutions, etc.).
We also use third-party cookies on the Site.
- Professional Advisors. We may disclose your personal data to
professional advisors, such
as lawyers, bankers, auditors and insurers, where necessary in the course of the
professional services that they
render to us.
- Third-party Applications and Integrations. For the provision of
the Service we receive and
share data with integrations and apps linked by customers (Facebook, Instagram,
WhatsApp, Telegram, Stripe,
etc.)
- Business Transfers. As we develop our business, we might sell or
buy businesses or assets.
In the event of a corporate sale, merger, reorganization, dissolution or similar event,
personal data may be
part of the transferred assets. You acknowledge and agree that any successor to or
acquirer of Talenthon (or
its assets) will continue to have the right to use your personal data and other
information in accordance with
the terms of this Privacy Policy. Further, Talenthon may also disclose aggregated
personal data in order to
describe our Service to prospective acquirers or business partners.
- Compliance with Laws and Law Enforcement. Talenthon may
disclose information about you
to government or law enforcement officials or private parties as required by law, and
disclose and use such
information as we believe necessary or appropriate to (a) comply with applicable laws
and lawful requests and
legal processes, such as to respond to subpoenas or requests from government
authorities; (b) enforce the terms
and conditions that govern the Service; (d) protect our rights, privacy, safety or
property, and/or that of you
or others; and (e) protect, investigate and deter against fraudulent, harmful,
unauthorized, unethical or
illegal activity.
Your Data Protection Rights & Choices
You have the following rights:
- If you wish to access your personal data that Talenthon
collects, you can do so
at any time by contacting us.
- You can also contact us to update, correct or
delete information in your account.
- If you are in the UK, you can object to processing of your
personal data, ask us
to restrict processing of your personal data
or request
portability of your personal data where it is technically possible.
- Similarly, if you are in the UK and provided we have collected and processed your
personal data under your
consent, then you can withdraw your consent at any time.
Withdrawing your consent
will not affect the lawfulness of any processing we conducted prior to your withdrawal,
nor will it affect
processing of your personal data conducted in reliance on other lawful processing
grounds.
- You have the right to complain to a data protection
authority about our collection
and use of your personal data. Contact details for data protection authorities are
available here.
You may submit your request via by sending an email to info@talenthon.co.uk. We will respond to
all requests in
accordance with applicable data protection laws.
Access to Data Controlled by our Customers. We don’t have any direct
relationships with customers’
Subscribers, i.e. the individuals whose personal data is stored by our customers the
Service. An individual who
seeks access, or who seeks to correct, amend, or delete personal data processed in the
Service by our customers
should direct their request to the customer directly.
Mode and place of processing the Data
1. Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
2. Place
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
3. Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.
Additional information about Data collection and processing
1. Legal action
The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities
2. Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
3. System Logs and Maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).
4. Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
5. The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.
6. Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.
7. Information about this privacy policy
The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda's servers.