1.Definitions and Interpretation
In this document the following terms shall have the assigned meanings:
|“Account”||Means: An account required to access and/or use certain areas and features of Our Products.|
|“Cookie”||Means: A small text file placed on your computer or device by Our Product when you visit certain parts of Our Product and/or when you use certain features of Our Product. Details of the Cookies used by Our Product are set out in section 11, below.|
|“GDPR”||Means: the General Data Protection Regulation (Regulation EU 2016/679).|
|“Local Storage”||Means: Some web applications can store data locally within the user’s browser. Before HTML5, application data had to be stored in ‘cookies’, included in every server request. Local Storage is more secure, and data can be stored locally, without affecting website performance.
Details of these files used by Our Site(s) are set out in section 11, below.
|“Our Products”||Means: Seahorse which an on line personality profiling software product developed and owned by Human Technology Limited, the Seahorse website and any related services.|
|“UK and EU Cookie Law”||Means: The relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.|
|“We/Us/Our/ or The Company”||Means: Human Technology Limited. A limited company registered in England. Reg no: 10691942, whose registered address is C/O Smith And Williamson, 25 Moorgate, London, United Kingdom, EC2R 6AY.|
2. Information About Us
2.1 Our Products are owned and operated by Human Technology Limited, a limited company registered in England under Reg. no: 10691942, whose registered address is C/O Smith And Williamson, 25 Moorgate, London, United Kingdom, EC2R 6AY. Our VAT number is 271862585.
2.2 We are registered as a data controller with the Information Commissioner’s Office (No. ZA256808).
2.3 We are compliant with the Data Protection Act 1998 and the GDPR.
3. Scope – What Do These Policies Cover?
3.3 If you are aged under 16 years, you MUST NOT use Our Products. If you are under 16 years old, and you are using any of Our Products, please stop using them immediately; then please email firstname.lastname@example.org stating your name and the email address used for registration, in order that we can delete your account as soon as reasonably possible, without further involvement by you.
3.4 If you do use any of Our Products, you warrant that you are over 16 years old.
4. What Data Do We Collect?
Some data will be collected automatically by Our Products. Other data will only be collected if you voluntarily submit it, for example when signing up for an Account. We may collect some or all of the following data:
Data submitted by you:
4.1 Your Name or Nickname provided in the registration field(s).
4.2 Your Job Title.
4.3 Your Business / company name.
4.4 Your email address or a messaging service identifier.
4.5 Payment data for example your credit card number if you choose to pay online for Our Products.
4.6 Anonymised responses to questions, statements and narratives sent by you as a result of undertaking personality questionnaires or responding to statements and narratives presented by Our Products
Data collected by our Products
4.7 Metadata collected for the statistical analysis and quality improvement of personality questionnaires; e.g. time taken for you to complete a question, occasions where questions were revisited, time taken to complete a set of questions, etc.
4.8 Names and / or contact details from your online address book where you have given us your express permission to do so
4.9 Anonymised information from your message service server where you have given us your express permission to do so
4.10 IP address – automatically collected for security and statistical purposes only.
4.11 Web browser type and version (automatically collected).
4.12 Operating system (automatically collected).
4.13 Recording the types of device used to access Our Products (e.g. Mobile, tablet, desktop etc).
4.15 See section 11 for more information about the cookies which are used in this site.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the principles of the Data Protection Act 1998 and the GDPR. For more details on security see section 6, below.
5.2 We use your data to provide the best possible products and services to you. This includes:
5.3 Providing and managing your Account.
5.4 Providing and managing your access to Our Products.
5.5 Supplying Our Products and services to you.
5.6 Personalising and tailoring Our Products and services for you.
5.7 To send you marketing communications about Our Products and other similar products we own.
5.8 Generalized server-side market research analysis (e.g. statistical metadata information about a user’s time spent on site or product, time logged in etc.).
5.9 Analyzing your use of Our Products and gathering feedback to enable Us to continually improve Our Products and your user experience.
5.10 To create a personality profile in order to assist users of Our Products to understand themselves and other users of Our Products, in order to create harmonious channels of communication between users wherever possible. (see 5.5)
5.11 Only with your express permission, subject to opt out at any time, and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or post with information, news and offers on Our Products and other products we own. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and the GDPR.
5.12 Advertisers whose content appears on Our Products may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using ‘local storage’ as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Products.
5.13 The data gathered from the server of your message service provider will be used to analyse your written language style, in terms of punctuation and other elements in the way you communicate in messages you have sent. This process is automated, it cannot ‘read’ your messages, and does not store the information in any form readable by a human being. The results of this analysis will be used to allocate a personality character or descripiton to you which is presented by Our Products.
5.14 The data gathered from your online address book will be used to enable you to select email addresses from your contacts to share your seahorse character with.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
6.2 We will not store or transfer your data outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Products.
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may share certain data with other companies in Our group. This will never be data that can render a data subject identifiable.
7.2 The only people other than you, who may be able to see information about you, are those whom you have expressly enabled to do so (i.e, you have shared your profile in a ‘social media’ context) either by inviting them to join Our Products or by sharing your profile on Social Media.
7.3 We may sometimes contract third parties to supply products and services to you on Our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under any appropriate law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
9. How can you control your data?
9.1 You will have the right to close your account at any time and to request the removal or archiving of your data by contacting Us using the contact details shown above.
10. How Can You Access Your Data?
10.1 You have the legal right to ask for a copy of any of your personal data held by Us. This is normally free of charge, but repeated or duplicate requests may incur a fee. Please contact Us for more details using the contact details shown above.
11. What ‘Cookies’ and / or ‘Local Storage’ Files Do We Use and What For?
11.1 Our Products may place and access certain first party Local Storage files on your computer or device. These are those placed directly by Us and are used only by Us. We use Local Storage to facilitate and improve your experience of Our Site and to provide and improve Our Products. For more details, please refer to section 5, above, and to section 11.4 below.
11.2 All Local Storage used by and on Our Site(s) are used in accordance with current UK and EU Law.
11.3 Certain features of Our Product depend on Local Storage files in order to function. UK and EU Law deems these files to be “strictly necessary”. The intention and use of these files are dynamic in nature, and are shown below in section 11.4. This section may well change occasionally, depending upon the data required by the site or product in question. Your consent will not be sought to place these files; however, you may still block these Local Storage files by changing your internet browser’s settings. Please be aware that Our Site(s) and / or Product(s) may not work as intended if you elect to do this. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.4 The following Local Storage files and third party cookies maybe placed on your computer or device.
.AspNet.ApplicationCookie This cookie is encrypted by OWIN used by Asp.Net Identity.
ARRAffinity Affinity Cookies are used to aid people who need to stay with a certain instance of web app or web site in Azure.
ASP.NET_SessionId ASP.Net_SessionId is a cookie which is used to identify the users session on the server. The session being an area on the server which can be used to store data in between http requests.
RequestVerificationToken It has anti forgery token (prevent CSRF attack). It guarantees that the poster is the one who gets the form.
ga Created by analytics.js (Google Analytics) to store the Client ID, but the cookie’s name, domain, and expiration time can all be customized.
ajs_anonymous_id analytics.js generates a UUID and sets this as anonymousId for all new visitors to your site.
ajs_group_id This doesn’t currently store anything.
ajs_user_id Created by analytics.js to collect data about user’s usage.
amplitude_id The custom name for the Amplitude cookie. Amplitude is used to capture user events.
intercom-id-cgfc6jcc intercom-*, Cookies set by intercom for its real time support chat system.
mp_ddef6d774d01618cb8afcb315f067d29_mixpanel Used by Mixpanel Tracks site navigation, responsiveness, and other metrics to helps improve visitors’ experience on our sites
11.5 You can choose to enable or disable Local Storage files in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all such files or only third-party cookies. By default, most internet browsers accept such files, but this setting can be changed. For further details, please consult the help menu in your internet browser or the documentation provided with your device.
11.6 You can choose to delete Local Storage files at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
11.7 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Contacting Us
This Policy shall be deemed effective as of 21st December 2017 No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.