PRIVACY POLICY
This policy sets out:
(1) the information we collect about you when you
visit our website, use our products or services, or otherwise interact with us:
(2) how we use, share, store, and secure the
information; and
(3) how you may access and control the information.
In this policy, "SubsTribe" or "we"
refers to M4trix Dev Limited of 71-75 Shelton Street Covent Garden London WC2H
9JQ (Company Number 12342375) and "Platform" means our
website at substribe.co.uk and substribe.net and our software,
namely SubsTribe Business App.
In this policy, "personal information" refers to
any data, information, or combination of
data and information that is provided by you to us, or
through your use of our products or
services, that relates to an identifiable individual.
1. WHAT INFORMATION WE COLLECT ABOUT YOU
1.1. We
collect the following types of information about you:
(a) account and profile information that you provide
when you register for an account or sign up for out products and services, for
example your name, username or similar identifier, other personal description,
job title, date of birth, physical address (billing or delivery or both), email
address, telephone numbers) (collectively, "Account Data");
(b) information you provide through support
channels, for example when you report a problem to us or interact with our
support team, including any contact information, documentation, or screenshots
(collectively, "Support Data");
(c) content you provide through use of our products
or services, for example Product listing, comments, discussion forum
(collectively, "User Content");
(d) communication, marketing, and other preferences
that you set when you set up your account or profile, or when you participate
in a survey or a questionnaire that we send you (collectively, "Preference
Data"); (e) details of any transactions, purchases, or
orders that you've made with us (collectively, "Transaction Data");
(f) payment information, for example Payment card
information (collectively, "Financial Data");
(g) information about your device or connection, for
example your internet protocol (IP) address, log-in data, browser type and
version, time-zone setting, browser plug-in types and versions, operating
system and platform, and other technology on the devices you use to access our
products or services and information we collect through cookies and other data
collection technologies (please read our Cookies Policy for details)
(collectively, "Technical Data"); and
(h) Information about your use of or visit to our
Platform, for example your clickstream to, through, and from our Platform,
products you viewed, used, or searched for, page response times, download
errors, length of visits to certain pages, page interaction information (such
as scrolling, clicks, and mouse-overs), or methods to browse away from the page
(collectively, "Usage Data").
(i) business partners and service providers based in
UK, Europe and USA who provide technical, payment, delivery services,
advertising networks, analytics, market research, and search information
services.
1.2. We
do not collect sensitive data or special category data about you. This includes
details about your race, ethnic origin, politics, religion, trade union
membership, genetics, biometrics, health, or sexual orientation.
2. HOW WE USE INFORMATION WE COLLECT
2.1. We
only use your personal information where the law allows us to. We use your personal
information only where:
(a) we need to perform the contract we have entered
into (or are about to enter into) with you, including to operate our products
or services, to provide customer support and personalised features, and to
protect the safety and security of our Platform;
(b) it satisfies a legitimate interest which is not
overridden by your fundamental rights or data protection interests, for example
for research and development, and in order to protect our legal rights and
interests
(c) you've given us consent to do so for a specific
purpose, for example we may send you direct marketing materials or publish your
information as part of our testimonials or customer stories to promote our
products or services with your permission; or
(d) we need to comply with a legal or regulatory
obligation.
2.2. If
you have given us consent to use your personal information for a specific purpose,
you have the right to withdraw your consent any time by contacting us (please
refer to paragraph 9 for contact information), but please note this will not affect
any use of your information that has already taken place.
2.3. We
do not share your personal information with any company outside our group for marketing
purpose, unless with your express specific consent to do so. We have set out
our legal bases for processing your information in the Legal Bases Table at the
end of this policy.
3. HOW WE SHARE INFORMATION WE COLLECT
3.1. We
share information with other companies in our group in order to operate our Platform
and to offer and improve our products and services.
3.2. We
share information with third parties that help us operate, provide, support, improve,
and market our products and services, for example third-party service providers
who provide Website and application development, data storage and backup,
infrastructure, billing, payment processing, customer support, business analytics,
and other services.
3.3. Third-party
service providers have access to your personal information only for the purpose
of performing their services and in compliance with applicable laws and regulations.
We require these third-party service providers to maintain confidentiality and
security of all personal information that they process on our behalf and to
implement and maintain reasonable security measures to protect the confidentiality,
integrity, and availability of your personal information.
3.4. We
take reasonable steps to confirm that all third-party service providers that we
engage process personal information in the manner that provides at least the
same level of protection as is provided under this policy. Where any
third-party provider is unable to satisfy our requirements, we will require
them to notify us immediately and we will take reasonable steps to prevent or
stop non-compliant processing.
3.5. We
may share personal information on aggregated or de-identified basis with third parties
for research and analysis, profiling, and similar purposes to help us improve our
products and services.
3.6. If
you use any third-party software in connection with our products or services,
for example any third-party software that our Platform integrates with, you
might give the third-party software provider access to your account and
information. Policies and procedures of third-party software providers are not
controlled by us, and this policy does not cover how your information is
collected or used by third-party software providers. We encourage you to review
the privacy policies of third-party software providers before you use the
third-party software.
3.7. Our
Platform may contain links to third-party websites over which we have no control.
If you follow a link to any of these websites or submit information to them. your
information will be governed by their policies. We encourage you to review the privacy
policies of third-party websites before you submit information to them.
3.8. We
may share your information with government and law enforcement officials to comply
with applicable laws or regulations, for example when we respond to claims,
legal processes, law enforcement, or national security requests
3.9. If
we are acquired by a third party as a result of a merger, acquisition, or
business transfer, your personal information may be disclosed and/or
transferred to a third party in connection with such transaction. We will
notify you if such transaction takes place and inform you of any choices you
may have regarding your information.
4. HOW WE STORE AND SECURE INFORMATION WE
COLLECT
4.1. We
use data hosting service providers based in USA to host the information we collect.
We have adopted the following measures to protect the security and integrity of
your personal information:
(a) information is encrypted using TLS/SSL
technology;
(b) access to your personal information is
restricted to personnel or service providers on a strictly need-to-know basis,
who will only process your information on our instructions and who are subject
to a duty of confidentiality; and
(c) our information collection, storage, and
processing practices are reviewed regularly.
4.2. We
have put in place procedures to deal with any suspected privacy breach and will
notify you and any applicable regulator of a breach where we are legally required
to do so.
4.3. While
we implement safeguards designed to protect your information, please note that
no transmission of information on the Internet is completely secure. We cannot guarantee
that your information, during transmission through the Internet or while stored
on our systems or processed by us, is absolutely safe and secure.
4.4. We
only retain personal information for so long as it is reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements. After such time, we will delete or anonymise
your information, or if this is not possible, we will securely store your information
and isolate it from further use. We periodically review the basis and appropriateness
of our data retention policy.
5. HOW WE TRANSFER INFORMATION
INTERNATIONALLY
5.1. We
collect information globally and primarily store that information in USA. We transfer,
process, and store your information outside your country of residence where we
or our service providers operate for the purpose of providing our products and
services to you.
5.2. Some
of the countries in which our companies or service providers are located may not
have the privacy and data protection laws that are equivalent to those in your country
of residence. When we share information with these companies or service providers,
we make use of contractual clauses, corporate rules, and other appropriate
mechanisms to safeguard the transfer of information.
6. YOUR RIGHTS
6.1. You
have the right to:
(a) be informed of what we do with your personal
information;
(b) request a copy of personal information we hold
about you;
(c) require us to correct any inaccuracy or error in
any personal information we hold about you;
(d) request erasure of your personal information
(note, however, that we may not always be able to comply with your request of
erasure for record keeping purposes, to complete transactions, or to comply
with our legal obligations);
(e) object to or restrict the processing by us of
your personal information (including for marketing purposes);
(f) request to receive some of your personal
information in a structured, commonly used, and machine-readable format, and
request that we transfer such information to another party; and
(g) withdraw your consent at any time where we are
relying on consent to process your personal information (although this will not
affect the lawfulness of any processing carried out before you withdraw your
consent).
6.2. Our
Platform enables you to update certain information about yourself, for example you
may change your business or personal information by emailing our customer service
at support@m4trixdev.com to update your records.
6.3. You
may opt out of receiving marketing materials from us by using the unsubscribe link
in our communications, by updating your preferences within your account on our
Platform or within your Pass preferences, or by contacting us. Please note, however,
that even if you opt out from receiving marketing materials from us, you will
continue to receive notifications or information from us that are necessary for
the use of our products or services.
6.4. As
a security measure, we may need specific information from you to help us confirm
your identity when processing your privacy requests or when you exercise your
rights.
6.5. Any
request under paragraph 6.1 will normally be addressed free of charge. However,
we may charge a reasonable administration fee if your request is clearly unfounded,
repetitive, or excessive.
6.6. We
will respond to all legitimate requests within one (1) month. Occasionally, it may
take us longer than a month if your request is particularly complex or if you have
made a number of requests
7. CHANGES TO THIS POLICY
7.1. We
may amend this policy from time to time by posting the updated policy on our Platform.
By continuing to use our Platform after the changes come into effect, you agree
to be bound by the revised policy.
8. POLICY TOWARDS CHILDREN
8.1. Our
products and services are not directed to individuals under 18. We do not knowingly
collect personal information from individuals under 18. If we become aware that
an individual under 18 has provided us with personal information, we will take
steps to delete such information. Contact us if you believe that we have mistakenly
or unintentionally collected information from an individual under 18.
9. CONTACT US
9.1. Please
contact us at support @ m4trixdev.com
9.2. Please
contact us in the first instance if You have any questions or concerns. If you have
unresolved concerns, you have the right to file a complaint with a data protection
authority in the country where you live or work or where you feel your rights
have been infringed. If you reside in the United Kingdom, you may file complaint
to the Information Commissioner's Office (CO), the UK supervisory authority for
data protection issues (www.ico.org.uk)
Last update 19 November
2021
COOKIES POLICY
Cookies are small text files that are placed on your device
by a web server when you access our Platform.
We use cookies to identify your
access and monitor usage and web traffic on our Platform to customise and
improve our products and services.
We use both persistent cookies and session cookies. A
persistent cookie stays in your browser and will be read by us when you return
to our Site or a partner site that uses our services.
Session cookies only last
for as long as the session lasts (usually the current visit to a website or a
browser session).
We use the following types of cookies:
a) Strictly necessary cookies - these are
cookies that are required for the operation of our site. They include, for
example, cookies that enable you to log into secure areas of our website.
b) Analytical/performance cookies - these
allow us to recognise and count the number of visitors and to see how visitors
move around our Site when they are using it. This helps us to improve the way
our site works, for example, by ensuring that users are easily finding what
they are looking for.
c) Functionality cookies - these are used to
recognise you when you return to our site.
d) Targeting cookies - these cookies record
your visit to our site, the pages you have visited, and the links you have
followed.
You can block cookies by activating the setting on your
browser that allows you to refuse the use of all or some cookies. However, if
you do so, you may not be able to access all or parts of our site.