UPDATED JULY 4th 2018
Types of Data collected
Among the types of Personal Data that Inkstinct collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, phone number, email address, various types of Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geographic position, username, Camera permission, Precise location permission (non-continuous), Phone permission, Social media accounts permission and Data communicated while using the service.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Inkstinct.
Unless specified otherwise, all Data requested by Inkstinct is mandatory and failure to provide this Data may make it impossible for Inkstinct to provide its services. In cases where Inkstinct specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through Inkstinct and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Inkstinct (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Data transfer outside the EU, Displaying content from external platforms, Remarketing and behavioral targeting, SPAM protection, Handling payments, Advertising, Infrastructure monitoring, Access to third-party accounts, Content commenting, Content performance and features testing (A/B testing), Device permissions for Personal Data access, Hosting and backend infrastructure, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, RSS feed management and Tag Management.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Facebook permissions asked by Inkstinct
Inkstinct may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Inkstinct to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Provides access to the User’s current location.
Provides access to the User’s primary email address.
Provides access to the User’s list of interests.
Provides access to the list of all of the pages the User has liked.
Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.
Device permissions for Personal Data access
Depending on the User’s specific device, Inkstinct may request certain permissions that allow it to access the User’s device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of Inkstinct.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Inkstinct.
Used for accessing the camera or capturing images and video from the device.
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Precise location permission (non-continuous)
Used for accessing the User’s precise device location. Inkstinct may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Inkstinct to derive the exact position of the User on a continuous basis.
Social media accounts permission
Used for accessing the User’s social media account profiles, such as Facebook and Twitter.
Owner and Data Controller
Inkstinct, Inc. – Manchester, MA 01944
Owner contact email: email@example.com