ChatSpin Privacy Policy

Last Updated: May 1, 2019

Introduction

Welcome to the Cogroup Limited privacy policy.

Cogroup Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our mobile application and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.Important information and who we ares

Purpose of this privacy policy

This privacy policy aims to give you information on how Cogroup Limited collects and processes your personal data through your use of the Chatspin website and mobile application, including any data you may provide when you sign up or purchase a membership.

Chatspin is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Cogroup Limited is the controller and responsible for your personal data (collectively referred to as “Cogroup Limited,” “we,” “us,” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your EEA/UK legal rights, please contact the data privacy manager using the details stated below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Cogroup Limited

Email address: privacy@chatspin.com

Postal address: Office 3, Unit R, Imperial Way, Penfold Works, Watford, United Kingdom, WD24 4YY

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you reside within the EEA, you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See http://ec.europa.eu for those details. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on May 1, 2019. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third-party links

Chatspin may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. In addition, Chatspin may include links to third-party plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

2.The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes username or similar identifier and gender.

  • Contact Data includes email address.

  • Financial Data includes payment card details. We store only very limited, if any, Financial Data. Otherwise, all Financial Data is stored by our payment processor, SegPay, and you are encouraged to review its privacy policy, which is located at https://segpay.com/consumer-privacy.html, and contact SegPay directly for responses to your questions.

  • Transaction Data includes details about payments from you and other details of products and services you have purchased from us.

  • Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Chatspin, including your webcam and microphone.

  • Device Data includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and IP address.

  • Content Data includes information stored on your computer, mobile telephone, or handheld device, including login information, photos, videos, or other digital content streamed or broadcast on Chatspin (please remember that Content Data may reveal personal data about yourself as well), and access to camera and microphone.

  • Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback, and survey responses.

  • Usage Data includes information about how you use our website, mobile application, products, and services, including traffic data and other communication data and the resources that you access.

  • Google Login Data includes your email address and password if you choose to link your Google account with us to facilitate account creation and logon process.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Location Data: includes your current location disclosed by GPS technology and IP address, as well as information about proxies.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Chatspin feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) unless you voluntarily provide it. Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3.How is your personal data collected?

We use different methods to collect data from and about you, including through:

  • Direct interactions. You may give us your Identity, Contact, Financial, and Marketing and Communications Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:

    • purchase products or services;

    • create an account on Chatspin;

    • use Chatspin (even if you don’t signup);

    • download the mobile application;

    • make an in-App purchase;

    • share data via social media functions;

    • request marketing to be sent to you;

    • enter a competition, promotion, or survey;

    • report a problem; or

    • give us feedback or contact us.

  • Automated technologies or interactions. As you interact with Chatspin, we will automatically collect Technical, Device, Content, and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical, Device, and Usage Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

  • Location Data. We also use GPS technology and your IP address to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

    • Technical Data from the following parties:

      • analytics providers such as Google based outside the EU; and

      • search information providers such as Google based outside the EU.

    • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services such as SegPay based outside the EU. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

    • Identity, Contact, and Profile Data from Google based outside the EU if you choose to register and login using your Google account.

4.How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where you have consented before the processing.

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new member

(a) Identity

(b) Contact

Performance of a contract with you

To install the mobile application and register you as a new app user

(a) Identity

(b) Contact

(c) Device

Your consent

To process and deliver your order including:

(a) Manage payments, fees, and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Device

(f) Marketing and Communications

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Communicate with you

(c) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Your consent

(b) Performance of a contract with you

(c) Necessary to comply with a legal obligation

(d) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in Chatspin’s interactive features, including enabling live video chat

(a) Identity

(b) Technical

(c) Device

(d) Content

(e) Profile

(f) Usage

(g) Marketing and Communications

(h) Location

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to offer you products and services)

To enable you to partake in a prize draw, competition, or complete a survey

(a) Identity

(b) Contact

(c) Device

(d) Profile

(e) Usage

(f) Marketing and Communications

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business)

To administer and protect our business and Chatspin (including security, fraud, troubleshooting/technical support, data analysis, testing, system maintenance, support, reporting, and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Device

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant content to you

(a) Identity

(b) Contact

(c) Technical

(d) Device

(e) Content

(f) Profile

(g) Usage

(h) Location

(a) Your consent

(b) Necessary for our legitimate interests (to study how customers use our products/services, and to develop them, to grow our business)

To use data analytics to improve our website, mobile application, products/services, marketing, customer relationships, and experiences

(a) Technical

(b) Device

(c) Usage

(d) Location

(a) Your consent

(b) Necessary for our legitimate interests (to define types of customers for our products and services, to keep Chatspin updated and relevant, to develop our business, and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Device

(e) Content

(f) Usage

(h) Marketing and Communications

(a) Your consent

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)

To facilitate account creation and logon process if you choose to register or log in to Chatspin using your Google account

(a) Google Login Data

(a) Performance of a contract with you

(b) Your consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Device, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into Chatspin and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing messages sent to you, or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience, or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes stated in the table (Purposes for which we will use your personal data) above.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.International transfers

We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.

If you are located in the European Economic Area (EEA) or United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.

Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.

7.Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Chatspin, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

We will collect and store personal data on your mobile or handheld device using application data caches and browser web storage (including HTML5) and other technology.

Certain services include social networking, chat, comment, or timeline features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected, or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for seven years after they stop being customers for tax purposes.

In some circumstances you can ask us to delete your data: see accessing and correcting your personal data and your EEA/UK legal rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.Accessing and correcting your personal data

You can access, review, and change your personal data by logging in and visiting your account profile page.

You may also send us an email at privacy@chatspin.com to request access to, correct, or delete any personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

If you delete your User Contributions from Chatspin, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Chatspin users.

California, Canadian, EEA, and UK users may have additional personal information rights and choices. Please see below for more information.

10.Do Not Track policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

11.Your California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the name and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided above.

12.Your Canadian privacy rights

We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.

We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.

Residents of Canada are notified that the personal data they provide to us is stored in our databases outside of Canada and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.

You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.

You have the right to complain about our personal data handling practices.

If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at privacy@chatspin.com. You may visit www.priv.gc.ca for more information about your privacy rights.

13.Your EEA/UK legal rights

If you reside in the EEA or UK, under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14.Glossary

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed, and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

  • Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the website, which will enable them to collect data about how you interact with the website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here: https://www.google.com/int’l/en/policies/privacy/). You can also optout of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Your EEA/UK Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data’s accuracy;

  • Where our use of the data is unlawful but you do not want us to erase it;

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Available on These Devices