SAFE TO WALK –
PRIVACY POLICY

Last updated 18 April 2019

This Privacy Policy informs why and how Safetowalk collects, uses or shares personal data and what rights you have.

The Service may contain links to websites and services of third parties. These websites or services are subject to their own privacy statements. Safetowalk does not take any responsibility of third parties’ privacy statements or processing of personal data in third parties’ operations. Please pay attention to their respective privacy statements and subsequent changes to thereto.

  1. DATA CONTROLLER

The data controller in accordance with the applicable law is Safetowalk(hereinafter together “Safetowalk“, “we“, “us” or “our“). Safetowalk is responsible for ensuring that the processing of personal data complies with this Privacy Policy and applicable data protection legislation.

Contact details of the data controller:

Safetowalk Oy (Business ID 2913027-1)

Metallimiehenkuja 10, FI‑02150 Espoo, FINLAND

Contact person is: Kim Lerche, kim@safetowalk.com

 

  1. LEGAL BASIS AND PURPOSE OF PROCESSING PERSONAL DATA
    • Service provision

Primarily, the legal basis for processing of personal data is based on your contract or request to enter into an agreement concerning the use of the Service. We are processing personal data for the purpose of providing the Service you requested and all actions related to this. Your personal data is needed for example

  • to manage your account;
  • to collect service fees;
  • to use and access the Service, including to communicate with other Members and with us through the Service;
  • to prevent, detect and investigate potentially prohibited or illegal activities and overall to oversee that the Service is used in an appropriate manner and in conformity with the law and applicable Terms of Use.

To the extent your location data is collected, processing of personal data is based on your consent. You have a right to withdraw your consent at any time. You can also use the Service without activating the collection of the location data. However, please note that then you may not share your location with other Members and users of the Service.

  • Service development

We can process your personal data on the basis of our legitimate interest, such as for development purposes. We want to improve our Service, features and content, and to enable Members to enjoy and easily navigate the Service.We use this technical data to analyze use of the Service and to increase our Service’s functionality and user-friendliness, and to better tailor it to our Members’ needs. Therefore we may:

  • send updates and information, for example, tell about the Service updates and new features; and
  • measure and improve our Service and the use of the Service.

Should you like more information regarding the above referred legitimate interest, please contact the person named in Section 1 of this Privacy Policy.

 

  1. COLLECTION OF PERSONAL DATA

We collect your personal data in order to provide you the requested Service. We may collect your personal data through different means, which are explained below.

  • Categories of personal data

Necessary personal data you give us via the Service. The Service and its functionalities require the use of an account. When you register with us through the Service, login or logout (including all attempts) to or from the Service, when you choose to use the Service or when you contact another Member using the message feature of the Service or communicate with us through the Service, we may collect your personal information. This may include;

  • basic personal information, such as your name;
  • your contact details;
  • location data;
  • your contact list;
  • video recordings;
  • transactional information, such as credit card number;
  • correspondence through the Service.

Safetowalk automatically collects and processes the following technical data about the use of the Service:

  • IP address, device ID, device type, operating system used and application settings;
  • User activity and items ‘clicked’ on;
  • timestamps and log data relating to the use of the Service; and
  • location/country of origin.

Technical usage data may be personal data or when combined with other data it may become such. To the extent that technical usage data is deemed personal data, we will treat the combined data as personal data.

In addition, we may also collect personal data when you voluntarily give us such, for example complete surveys or provide feedback. This personal data is optional and not required in order to use the Service.

  • Special categories of personal data

We do not request or intend to collect any special categories of personal data, such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. Please be cautious when sharing this information about yourself (or others) in the Service.

Personal data listed above is collected directly from the Member in connection with the registration or use of the Service.

 

  1. SHARING OF PERSONAL DATA

We may disclose personal data to third parties:

  • when required by law such as to comply with a subpoena, requests by competent public authorities, or similar legal process;
  • with our trusted services providers who work on our behalf (e.g. Amazon), and who do not have an independent right use the information we disclose to them or;
  • if our company is involved in a merger, acquisition, or sale of all or a portion of its assets; or
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

 

  1. TRANSFERS OF PERSONAL DATA OUTSIDE OF EU/EEA

Personal data is processed within the European Economic Area.

 

  1. RETENTION OF PERSONAL DATA

We will retain your personal data as long as your account remains activated and after that in accordance with applicable laws, such as accounting laws. We will remove your data except when retention is required by law or rights or obligations by either party.

The Service allows you to store your video recordings for a longer period, if you wish to do so. This processing requires your consent. We note that you can also download the recordings to your own phone or device at any time.

 

  1. CHILDREN

The use of the Service by children under 13 years of age is subject to parental consent. At any time, parents can refuse to permit us to collect further personal data from their children in association with a particular account, and can request that we delete from our records the personal data we have collected in connection with that account.

 

  1. PRIVACY RIGHTS

Individuals have the following rights:

  • The right to request access to personal data about himself/herself;
  • The right to request rectification, restriction or erasure of personal data. However, please note that retention of certain information is strictly necessary in order to fulfil the purposes defined in this Privacy Policy and may also be required by law. Therefore, the deletion of such data may not be allowed by the applicable law, which prescribes mandatory retention periods;
  • The right to object for processing, that is based on legitimate interest of Safetowalk provided that the individual can demonstrate compelling legitimate grounds;
  • The right to object to processing for marketing purposes and prevent from receiving future direct marketing;
  • If processing of personal data is based on consent, the individual has the right to withdraw consent at any time. The withdrawal will not affect the lawfulness of the processing carried out before the withdrawal; and
  • Individuals have a right to data portability, i.e. right to receive the personal data in a structured, commonly used machine-readable format and transmit the personal data to another data controller, to the extent required by applicable law.

Please send above-mentioned requests to contact person named in Section 1 of this Privacy Policy.

Individuals have a right to file in a complaint to the national data protection authority in the EU/EEA.

 

  1. SECURITY

We maintain reasonable security measures (physical, electronic and procedural) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and contractors who have a need to know in order to operate, develop or improve the Service.

Please be aware that, although we endeavour to provide reasonable security for personal data we process and maintain, no security system can prevent all potential security breaches.

 

  1. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change and update this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you a notice through the Service or by some other reasonable means, such as by email.

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