Scattr Privacy Policy 08/05/2018

 

Devine Software Limited trading as Scattr ("we", "our" or "Scattr") provide a platform through our website and mobile application (“Sites”) for businesses (“Merchants”) to promote and market products and services and for users of Scattr (“Users”) to access promotional and marketing campaigns for such products and services (“Services”). We may sometimes in this policy refer to both Merchants and Users as “You”. In using our Services You will provide information to us, each other, other Users and sometimes third parties. This policy (“Privacy Policy”) sets out the basis on which we collect, use and transfer information. We are committed to protecting Your privacy. By using the Services, You agree and where required You consent to the collection, use and transfer of Your information as set out in this policy.

 

1.   Information we collect

 

1.1.1 Information you choose to give to us - Users

To set up an account on Scattr, we require some information such as an email address, a username you’d like to go to by, display name, your date of birth & your gender.

To make it easier for others to find you on Scattr, we may ask you to provide additional information that will be publicly visible on our Site(s) such as profile pictures or other useful identifying information. You may also want to provide a Facebook ID.

Other Services, such as Gift Cards, may require you to provide us with a debit or credit card number & its associated account information.

We will also ask you how you heard about the app, so we are able to monitor our own marketing campaigns.

Whenever you contact a member of our team, we will collect & store any information that you volunteer.

 

1.1.2 Information you choose to give to us – Merchants

To ensure you can utilise the Services provided by Scattr to you, we require you to agree to register an account with us and provide information to be held by us which may include but not limited to business name, address, contact name, email address, contact phone number, position in business, type of business and redemption code. You may also want to provide us with your website address, profile picture, description and location. If you are using the Gift Card Services, you will also provide us with a Gift Card contact name, email address, phone number & Gift Card validity period.

 

1.2.1 Information we collect when you use our Site(s) - Users

When you use our Site(s), we collect information about which of those Services you’ve used & how you’ve used them. For example, we might know which friends you’ve added on the app or which businesses you follow. Here’s a fuller explanation of the types of information we collect when you use our Services:

 

Usage information: We collect info about your activity through our Services. For example:

Š      How you interact with the Services, such as which businesses you follow, which parcels you open, which Feel Good Freebies you claim & which parcels you swipe up on to visit the website.

Š      How you communicate with other Users, such as their Usernames, the date & time of your communications, friend requests you send, Users that you block, the number of parcels you pass, and your interactions with parcels, gifts, feel good freebies (such as when you pass them on to a friend or redeem them).

Š      How you interact with Gift Cards, such as their value, business that they are for, the message & template that you attach & the friend that you send it to.

Š       Any content you create and send to other Users is done so at your own risk. We take no responsibility and cannot be held accountable for other Users extracting generated content from Scattr, such as screenshots.

 

Content information: We collect content you create on our Site(s), such as User parcels that you create & pass to other Users, the image/text inside it along with any labels included. We also collect information such as whether the recipient has opened the User parcel & if they edit it and/or pass it on to other Users.

Device information: We collect information about the devices that you use. For example, we collect:

Š      Information about your hardware & software, such the platform you are using, unique device identifiers, the version of the Site(s) you are using and the version of the operation system on your device.

Cameras and Photos: Some of our Services require us to collect images and other information about your device’s camera and photos. For example, you won’t be able to send User parcels or upload photos from your camera roll unless we can access your camera or photos.

Location information: When you use our services & with your consent, we may collect information about your location. This will be done using methods like GPS, wireless networks, cell towers and Wi-Fi access points. At any time, you can withdraw consent to our using and processing location information about you by not using the location-based features on the Sites and/or turning off location settings (as applicable) on your device.

 

1.2.2 Information we collect when you use our Site(s) – Merchants

When you use our Site(s), we collect information about which of those services you’ve used & how you’ve used them. For example, we might know information about your upcoming campaigns, or who’s in your business team. Here’s a fuller explanation about the type of information we collect when you use our services:

 

Usage information: We collect info about your activity through our services. For example:

Š      Campaign information, such as which ad template you have used, when it’s created, launched & ended, which User created/approved/declined it, gift information, claim information, Feel Good Freebie information, geographic targeting, and initial recipient information.

Š      Campaign statistics during/after a campaign has been launched. This will include how many opens/passes/website views the campaign has had & info on prize redemption.

Š      Gift Card information, such as who has purchased your Gift Cards, who they sent them to, their value & redemption details.

 

Content information: We collect content you create on our Site(s), such as ads made through the ad creator, or gift images uploaded to the campaign creation form.

 

2.   How we use this information

 

2.1 Users

By using the information that we collect, we can provide you with relevant access to the Site(s) and to supply the Services you have requested, and continue to improve these Services. Here are some of the ways we do that:

Š      We develop, operate, improve, deliver, maintain and protect all our products and services.

Š      We allow Merchants to provide you with the opportunity to enter promotional and marketing campaigns, and purchase Gift Vouchers or receive Promotional Vouchers from them.

Š      We send you communications, including via email. This includes to respond to enquiries, or share information about our products, Services and promotional offers that we think might interest you.

Š      We will also use and analyse the information we collect so that we can administer, support, improve and develop our business and Services. This includes the production of statistical information on recommendations of brands for the benefit of Merchants, the identification of trends and assessing the success rates of promotional and marketing campaigns and use of Promotional Vouchers and Gift Cards. We do not disclose your or other Users identities or other personal information to Merchants when doing so.

Š      We will personalise the Services, for example by suggesting friends or customising information that we show you.

Š      We provide and improve advert targeting and measurement, including through the use of your precise location data (only if you’ve consented to us collecting that data).

Š      We may verify your identity and prevent fraud or other unauthorised or illegal activity.

Š       We may use your information to contact you for your views on our Services and to notify you occasionally about important changes or developments to our Services.

Š       Users of the Services can see your username, display name, profile picture (if displayed) and Users you are friends with.

 

We do not combine specific User data collected to establish a profile of that User, such data is gathered on groups of Users to enable us to identify trends and for other business purposes and is not gathered on Users as individuals. Such data is aggregated or made anonymous such that it can no longer be reasonably associated with a specific User.

 

We may also store or use information locally on your device. For example, we may store information as local cache so that you can open the app and view content faster.

 

2.2  Merchants

By using the information that we collect, we can provide you with relevant access to the Site(s) and to supply the Services you have requested, and continue to improve these Services. Here are some of the ways we do that:

Š      We develop, operate, improve, deliver, maintain and protect all our products and services.

Š      We send you communications, including via email. This includes to respond to enquiries, or share information about our products, Services and promotional offers that we think might interest you.

Š      We will also use and analyse the information we collect so that we can administer, support, improve and develop our business and Services.

Š      We may verify your identity and prevent fraud or other unauthorised or illegal activity.

Š       We may use your information to contact you for your views on our Services and to notify you occasionally about important changes or developments to our Services.

 

 

3.   How we share this information

 

3.1 Users

We may share information about you in the following ways:

Š      With other Users:

o   Information about you, such as your username, display name & profile picture.

o   Information about how you’ve used the Services, such as the names of your friends. This is to help people recognize you if you send them a friend request.

Š      With the general public:

o   Public information that you consent us to share.

Š      With third parties:

o   Whilst using our Services you may make a transaction that involves a payment to a Merchant. Where such payment is made, it will be processed on a third party payment platform and not by us. You will be asked by the payment platform to supply personal information to enable payment (such as debit or credit card details) and this information will be held by that payment platform and not by us. The payment platform will have its own privacy policy and we would advise you to read that privacy policy before making payment on that platform.  

o   With third parties for legal reasons. _We may share information about you if we reasonably believe that disclosing the information is needed to:

§  comply with any valid legal process, governmental request, or applicable law, rule or regulation.

§  investigate, remedy, or enforce potential Terms of Service violations.

§  protect our, our Users' or others' rights, property and safety.

§  detect and resolve any fraud or security concerns.

Š       The information You provide to us will be transferred to and stored on our servers. If Scattr enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors. We may use the information that You provide to us if we are under a duty to disclose or share Your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce, as applicable, Scattr Terms of Use or Scattr Merchants Terms and Conditions and any other agreement; or to protect our rights. If we intend to transfer Your information outside the EEA (European Economic Area) we will always obtain Your consent first.

Š       We may also share with third parties – such as advertisers, analytics services, email marketing platforms – aggregated, non-personally identifiable or de-identified information.

 

3.2  Merchants

We may share information about you in the following ways:

Š      With our Users:

o   Information about you, such as your business name, description & profile picture.

o   Information about how you’ve used the Services, such as upcoming & previous campaigns that you have ran.

Š      With the general public:

o   Public information that you consent us to share.

Š      With third parties:

o   Whilst using our Services you may make a transaction that involves a payment to us or receive payment from a User. Where such payment is made, it will be processed on a third party payment platform and not by us. You will be asked by the payment platform to supply personal information to enable payment (such as debit or credit card details) and this information will be held by that payment platform and not by us. The payment platform will have its own privacy policy and we would advise you to read that privacy policy before making payment on that platform.  

o   With third parties for legal reasons. _We may share information about you if we reasonably believe that disclosing the information is needed to:

§  comply with any valid legal process, governmental request, or applicable law, rule or regulation.

§  investigate, remedy, or enforce potential Terms of Service violations.

§  protect our, our Users' or others' rights, property and safety.

§  detect and resolve any fraud or security concerns.

Š       The information you provide to us will be transferred to and stored on our servers. If Scattr enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors. We may use the information that You provide to us if we are under a duty to disclose or share Your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce, as applicable, Scattr Terms of Use or Scattr Merchants Terms and Conditions and any other agreement; or to protect our rights. If we intend to transfer Your information outside the EEA (European Economic Area) we will always obtain Your consent first.

Š       We may also share with third parties – such as advertisers, analytics services, email marketing platforms – aggregated, non-personally identifiable or de-identified information.

 

 


 

4.   How long we keep your content

We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will keep your information for a reasonable period or as long as the law requires.

Where you have chosen a password which allows you to access our Services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. If you have reason to believe that your interaction with us is no longer secure please contact us immediately by emailing info@scattr.io.

 

5.   Control over your information

We want you to be in control of your information, so we provide you with the following tools.

Access and updates. We strive to let you access and update most of the personal information that we have about you. However, there are limits to the requests we’ll accommodate. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful. You can access and update most of your basic account information right in the app by visiting the app’s Settings page. If you need to access, update or delete other personal information that we may have, you can email a request to info@scattr.io. We will comply with any such request within 1 month of it being received. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access or update your personal information. We will try to update and access your information for free, but if it would require a disproportionate effort on our part, we may charge a fee. We will of course disclose the fee before we comply with your request. We reserve the right to refuse any request that is manifestly unfounded or excessive.

Revoking permissions. If you change your mind about our ongoing ability to collect information from certain sources that you have already consented to, such as your email marketing permissions or location services, you can simply revoke your consent by changing the settings on your device. Of course, if you do that, certain services may lose full functionality.

Account deletion. Although we hope you’ll remain a lifelong User, if for some reason you ever want to delete your account, send us an email to info@scattr.io.

Communicating with other Users. It’s also important to us that you stay in control over whom you communicate with. That’s why we’ve included functionality that lets you delete and/or block another user from your app’s Settings.

 

6.   Children

Our Services are not intended for anyone under the age of 13, so no Users under this age will be permitted to create an account. If you are above the age of 13 but under the age of 16, you can still create an account, but we will not knowingly collect personal information from anyone in this age range.

 

7.   Changes to our Privacy Policy

This Privacy Policy is effective as of 8th May, 2018 and will remain in effect except with respect to any changes in its provisions in the future, which will take effect as soon as they are posted on the Sites. We reserve the right to update or change our Privacy Policy at any time and You should check this Privacy Policy periodically. Your continued use of the Services after we post any modifications to the policy will constitute your acknowledgement of the modifications and your consent to abide and be bound by same.                 

                       

Any changes to our Privacy Policy will be posted to our Sites and, where appropriate, through electronic notification.