Privacy Policy

 

This policy describes the information we process to support Send It.

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I. What kinds of information do we collect?

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To provide Send It, we must process information about you. The types of information we collect depend on how you use Send It.

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Things you and others do and provide.

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• Information and content you provide. We collect the content, communications and other information you provide when you use Send It, including when you sign up for an account, share content, and message or communicate with others. This can include information in or about the content you provide (like metadata), such as the location of a photo or the date a file was created. Our systems automatically process content and communications you and others provide to analyse context and what's in them for the purposes described below. 

• Networks and connections. We collect information about the people you are connected to and how you interact with them using Send It, such as people or locations you interact with the most. We also collect contact information and upload it to our server if you choose to upload, sync or import it from a device (such as an address book), which we use for things like helping you and others find people you may know and for the other purposes listed below.

• Your usage. We collect information about how you use Send It, such as the content you view or engage with; the features you use; the actions you take; the people you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used Send It, and what check ins, images and other content you view on Send It.

• Things others do and information they provide about you. We also receive and analyse content, communications and information that other people provide when they use Send It. This can include information about you, such as when others send a message to you, or upload, sync or import your contact information.

• Contact information. 

 

Device Information

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As described below, we collect information from and about the device you use to access Send It.

Information we obtain from devices includes:

• Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, and plugins.

• Device operations: information about operations and behaviors performed on the device

• Identifiers: unique identifiers, device IDs.

• Device signals: Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers.

• Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.

• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.

• Cookie data: data from cookies stored on your device, including cookie IDs and settings.

 

Information from partners.

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Advertisers, app developers, and publishers can send us information. These partners provide information about your activities off Send It—including information about your device, websites you visit, purchases you make, the ads you see, and how you use their services—whether or not you have a Send It account or are logged into Send It. For example, a business could tell us about a purchase you made in its store. We also receive information about your online and offline actions and purchases from third-party data providers who have the rights to provide us with your information.

Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us.

 

 

II. How do we use this information?

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We use the information we have (subject to choices you make) as described below and to provide and support the Send It services described in the Send It Terms. Here's how:

Provide, personalize and improve Send It.

We use the information we have to deliver Send It, including personalising features and content and make suggestions for you on and off Send It. To create a personalised product that is unique and relevant to you, we use your connections and activities based on the data we collect and learn from you and others; how you use and interact with Send It; and the people, places, or things you're connected to and interested in on and off Send It. 

 

• Location-related information: We use location-related information-such as your current location, where you live, the places you like to go, and the businesses and people you're near-to provide, personalize and improve Send It, including ads, for you and others. Location-related information can be based on things like precise device location (if you've allowed us to collect it), IP addresses, and information from your and others' use of Send It (such as check ins).

• Product research and development: We use the information we have to develop, test and improve Send It, including by conducting surveys and research, and testing and troubleshooting new products and features.

• Ads and other sponsored content: We may use the information we have about you-including information about your interests, actions and connections-to select and personalise ads, offers and other sponsored content that we show you.

 

Provide measurement, analytics, and other business services.

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We use the information we have (including your activity off Send It, such as the websites you visit and ads you see) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps, and services.

 

Promote safety, integrity and security.

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We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of Send It, and promote safety and security on and off of Send It.

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Communicate with you.

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We use the information we have to send you marketing communications, communicate with you about Send It, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

 

Research and innovate for social good.

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We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

 

 

III. How is this information shared?

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Your information is shared with others in the following ways:

 

- Sharing on Send It

- People you share and communicate with

- When you share and communicate using Send It, your network can see actions you have taken on Send It.

- Content others share or reshare about you

- You should consider who you choose to share with, because people who can see your activity on Send It can choose to share it with others on and off Send It, including people and businesses outside the audience you shared with. For example, when you check in or send a message to specific friends, they can download, screenshot, or reshare that content to others across or off Send It. 

- People can also use Send It to create and share content about you with the audience they choose. For example, people can share a photo of you in a check in.

- Information about your active status or presence on Send It.

- People in your networks can see signals telling them whether you are active on Send It, including whether you are currently active on Send It, or when you last used Send It.

- Apps, websites, and third-party integrations on or using Send It.

- When you choose to use third-party apps, websites, or other services that use, or are integrated with, Send It, they can receive information about what you share. Also, when you download or use such third-party services, they can access your public profile on Send It, and any information that you share with them. Apps and websites you use may receive your list of Send It friends if you choose to share it with them. But apps and websites you use will not be able to receive any other information about your Send It friends from you, (although your friends may, of course, choose to share this information themselves). Information collected by these third-party services is subject to their own terms and policies, not this one.

- Devices and operating systems providing native versions of Send It (i.e. where we have not developed our own first-party apps) will have access to all information you choose to share with them, including information your friends share with you, so they can provide our core functionality to you.

- New owner.

- If the ownership or control of all or part of Send It or their assets changes, we may transfer your information to the new owner.

 

Sharing with Third-Party Partners

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- We work with third-party partners who help us provide and improve Send It, which makes it possible to operate our companies and provide free services to people around the world. We don't sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:

- Partners who use our analytics services.

- We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their content on and off Send It. 

- Advertisers.

- We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. - For example, we provide general demographic and interest information to advertisers to help them better understand their audience. We also confirm which Send It ads led you to make a purchase or take an action with an advertiser.

- Measurement partners.

- We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners.

- Vendors and service providers.

- We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how Send It is used, providing customer service or conducting surveys.

- Researchers and academics.

- We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that support our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.

- Law enforcement or legal requests.

- We share information with law enforcement or in response to legal requests in the circumstances outlined below.

 

 

IV. What is our legal basis for processing data?

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We collect, use and share the data that we have in the ways described above:

• as necessary to fulfill our Send It Terms and Conditions

• as necessary to comply with our legal obligations

• to protect your vital interests, or those of others;

• as necessary in the public interest; and

• as necessary for our (or others') legitimate interests, including our interests in providing an innovative, personalised, safe, and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.

 

 

V. How can you exercise your rights provided under the GDPR?

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Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:

• the right to object to our processing of your data for direct marketing

• the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.

 

 

VI. Data retention, account deactivation and deletion

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We store data until it is no longer necessary to provide our services or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. 

When you delete your account, we delete things you have posted, such as your photos and check ins, and you won't be able to recover that information later. Information that others have shared about you isn't part of your account and won't be deleted. You can delete your account at any time in the Send It app.

 

 

VII. How do we respond to legal requests or prevent harm?

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We access, preserve and share your information with regulators, law enforcement or others:

• In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.

• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of Send It, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or services), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off Send It.

Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

 

 

VII. How do we operate and transfer data as part of our global services?

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We share information globally with our partners and with those you connect and share with around the world in accordance with this policy. Information controlled by Send It will be transferred or transmitted to, or stored and processed in any country outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide the services set forth in the Send It Terms and Conditions and to globally operate and provide Send It to you. We utilize standard contractual clauses approved by the European Commission and rely on the European Commission's adequacy decisions about certain countries, as applicable, for data transfers from the EEA to other countries.

 

 

IX. How will we notify you of changes to this policy?

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We'll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using Send It.

 

 

X. How to contact Send It with questions

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You can learn more about how privacy works on Send It. If you have questions about this policy, you can contact us as described below.

The data controller responsible for your information is Send It, which you can contact by email at hello@senditapp.co.uk

 

You also have the right to lodge a complaint with The Information Commissioner's Office (ICO) or your local supervisory authority.

 

 

Date of Last Revision: 4th July, 2020