UPDATED September 2018
Types of Data collected
Among the types of Personal Data that Tatted collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, phone number, email address, various types of Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geographic position, username, Camera permission, Precise location permission (non-continuous), Phone permission, Social media accounts permission and Data communicated while using the service.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Tatted.
Unless specified otherwise, all Data requested by Tatted is mandatory and failure to provide this Data may make it impossible for Tatted to provide its services. In cases where Tatted specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through Tatted and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Tatted (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 Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Data transfer outside the EU, Displaying content from external platforms, Remarketing and behavioral targeting, SPAM protection, Handling payments, Advertising, Infrastructure monitoring, Access to third-party accounts, Content commenting, Content performance and features testing (A/B testing), Device permissions for Personal Data access, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, RSS feed management and Tag Management.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Facebook permissions asked by Tatted
Tatted may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Tatted to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Provides access to the User’s current location.
Provides access to the User’s primary email address.
Provides access to the User’s list of interests.
Provides access to the User’s photos and videos.
Provides access to the list of all of the pages the User has liked.
Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.
Device permissions for Personal Data access
Depending on the User’s specific device, Tatted may request certain permissions that allow it to access the User’s device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of Tatted.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Tatted.
Used for accessing the camera or capturing images and video from the device.
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Precise location permission (non-continuous)
Used for accessing the User’s precise device location. Tatted may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Tatted to derive the exact position of the User on a continuous basis.
Social media accounts permission
Used for accessing the User’s social media account profiles, such as Facebook, Instagram, Tattodo, and Twitter.
Owner and Data Controller
Focwizard, Inc dba Tatted – 14 Bond St, #458, Great Neck, New York 11021, USA
Owner contact email: firstname.lastname@example.org
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
ACCESS TO THIRD-PARTY ACCOUNTS
This type of service allows Tatted to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Tatted)
This service allows Tatted to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Current City, Email, Interests, Likes, Photos, Videos, and Manage Pages.
CONTACTING THE USER
CONTENT PERFORMANCE AND FEATURES TESTING (A/B TESTING)
DATA TRANSFER OUTSIDE THE EU
DEVICE PERMISSIONS FOR PERSONAL DATA ACCESS
DISPLAYING CONTENT FROM EXTERNAL PLATFORMS
HOSTING AND BACKEND INFRASTRUCTURE
MANAGING CONTACTS AND SENDING MESSAGES
REMARKETING AND BEHAVIORAL TARGETING
REGISTRATION AND AUTHENTICATION
RSS FEED MANAGEMENT
Further information about Personal Data
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. Tatted may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. Tatted adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
• to enable or otherwise improve the decision-making process;
• to grant Users fair and unbiased treatment based on consistent and uniform criteria;
• to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
• to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Tatted, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
• obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
• challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
• request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
SELLING GOODS AND SERVICES ONLINE
UNIQUE DEVICE IDENTIFICATION
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Tatted or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, Tatted and any third-party services may collect files that record interaction with Tatted (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Tatted 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.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through Tatted (or third-party services employed in Tatted), which can include: the IP addresses or domain names of the computers utilized by the Users who use Tatted, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using Tatted who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Tatted. The Data Controller, unless otherwise specified, is the Owner of Tatted.
Tatted (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by Tatted as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
© 2018 Focwizard, Inc. dba Tatted