Effective as of 08.10.2018
Welcome to Vaciniti Media Limited! Thank you for choosing to use our services.
- Definitions The following terms shall have the following meaning:
“Service” or “Services“: access to our site www.vaciniti.com as well as your subscription to and any Order of our services, products, applications, tools, offline components and features (individually the “Service” or collectively, the “Services”) provided by our company Vaciniti Media Limited, together with its affiliates, officers, directors, employees, agents and subsidiaries (hereinafter “Vaciniti Media”, “we”, “our” or “us”).
“Application”: mobile or desktop application created by the User through Vaciniti Media and made available to the public for download from a third-party platform or accessible from a web browser
“User”: any person or entity having an account allowing access to our Services.
“End User”: Any person or entity who actually uses our Service(s). It can be users, visitors and customers of our User’s Application.
“Website User“: Any person visiting one of our websites
- Information we collect
2.1 Information you voluntarily provide to us
2.2 Information collected automatically
2.3 Information from your use of the Service
We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the Services. This type of information helps us to improve our Services for both you and for all of our users.
2.4 Cookies and tracking
2.5 Information from the use of our Applications
When you use our mobile apps (for instance No Team Left Behind), we may collect certain information in addition to information described elsewhere in this Policy. For example, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account. If you have opted in to these notifications and no longer want to receive them, you may turn them off through your operating system. We may ask for, access or track location-based information from your mobile device so that you can test location-based features offered by the Services or to receive targeted push notifications based on your location. If you have opted in to share those location-based information, and no longer want to share them, you may turn sharing off through your operating system. We may use mobile analytics software to better understand how people use our application. We may collect information about how often you use the application and other performance data.
- How we use collected information. We may use and disclose Personal Information for the following purposes:
3.1 To promote use of our Services to you and others. For example, if we collect your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using.
3.2 To bill and collect money owed to us by our Users. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
3.4 To communicate with our Users about their account and provide customer support.
3.6 To protect the rights and safety of our Users and third parties, as well as our own.
3.7 To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms. To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
3.8 To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
3.9 To provide, support, and improve the Services we offer. This includes our use of the data that our Users provide us in order to enable our Users to use the Services to communicate with their End Users. This also includes, for example, aggregating information from your use of the Services or visit to our Websites or Applications created with our Service and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your End Users with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
- Data Collected for and by our Users. As you use our Services, you may import into our system Personal Information you have collected from your End Users or other individuals. We have no direct relationship with your End Users or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 3, we may transfer Personal Information of you or your End Users to companies that help us promote, provide, or support our Services or the services of our Users (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about End users. We may share this information with third parties in line with the approved uses in Section 3.
If you are a End User and no longer want to be contacted by one of our Users, please contact the User directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the User of your request.
We will retain Personal Information we process on behalf of our Users for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
- Data controller and Data processor
The User as the Data Controller. Our Customers who have created an Application using Vaciniti Media are responsible for what they do with the personal information they collect, directly or through Vaciniti Media, about their End Users.
The User is the Data Controller and Vaciniti Media is the Data Processor.
You’re solely responsible for complying with any laws and regulations that apply to your collection and use of your End Users’ information, including personal information you collect about them using the Services or cookies or similar technologies.
We’re not liable for your relationship with your End Users or how you collect and use personal information about them (even if you collect it from us or using Vaciniti Media functionality or cookies or similar technologies) and we won’t provide you with any legal advice regarding such matters.
Vaciniti Media as the Data Controller. For Users and Website Visitors of any of our websites (for instance www.vaciniti.com), Vaciniti Media is the Data Controller.
- Your Rights You (in particular, European users) have certain legal rights to obtain information about whether we hold personal information about you, to access personal information we hold about you, and to obtain its correction, update, amendment or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).
Rights which you are entitled to are:
Data access rights
Right to restrict processing
Right of Rectification
Right to Erasure (Right to be Forgotten)
Right to object to processing
Right to withdraw consent; and
Data portability rights
Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.
If you are a User. You can access, update, change or delete personal information (or that of your End Users) either directly in your Account or by contacting us at dpo@Vaciniti Media.com to request the required changes. You can exercise your other rights (including deleting your Account) by contacting us at the same email address.
If you are a End User. Where you are using an Application made by one of our User, you will need to reach out directly to that User, the Data Controller, to discuss managing, deleting, accessing, restricting access to or otherwise withdrawing consent for use of, the information which you provided to them while using their Application. Vaciniti Media, as the Data Processor, is not in a position to directly handle these requests. If you are having difficulties finding this User you can contact us at email@example.com and we will try our best to help you.
Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
- How we protect your information. While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. More information can be found on the Data Processing Agreement (DPA)
- Public information and Third parties
8.1 Blog We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at firstname.lastname@example.org. If we are unable to remove your information, we will tell you why.
8.2 Social media platforms and widgets. Our Websites include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
8.4 Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature such as Social Profiles), then we may share your and/or your End-Users’ Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy.
- Your acceptance of these terms. By using our Services, you signify your acceptance of this policy and Terms of Service. If you do not agree to this policy, please do not use our Services. Your continued use of the Services following the posting of changes to this policy will be deemed your acceptance of those changes.