Effective Date: March 1, 2012
1. Who are we?
1.1 We are Snazaroo Holdings Ltd t/a Snazaroo. We own and operate this site and our app (we’ll call them our “site”). You can contact us at: at ColArt, The Studio Building, 21 Evesham Street, London W11 4AJ and by e-mail at: firstname.lastname@example.org . Please contact us if you have any questions or feedback about this policy. We’d be delighted to help.
1.2 We are registered with the UK Information Commissioner’s Register of Data Controllers under number 510 9650.
2. What’s the point of this policy?
2.1 The idea is that we tell you how we collect, use and disclose your “personal data”. (This is the technical term for information about any identified or identifiable living person). Please read on to find out what kinds of personal data we collect, how we use and protect it, to whom we disclose it and how you can access and rectify it.
3. Might the policy change?
3.1 It may well do and so you should check it whenever you visit our site. By using the site after the effective date shown at the top of the policy you’ve told us that you accept the then-current policy.
4. What personal or other data do we collect and how do we collect it?
4.1 We collect and store the information which you give us via forms on our site - such as your name, address, email address, phone number and so on – including the registration form, or when communicating with us by email or in some other way. Any information that identifies you or from which your identity can be deduced is considered “personally identifiable information” or “PII.”
4.2 We may automatically receive and store certain information that does not personally identify you when you interact with us. Examples include the internet protocol (IP) address used to connect your computer to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from our site (including date and time), cookie number, activity on our website including the pages you visited and searches you made.
5. What about cookies?
5.1 What are cookies? Cookies are simple text files which your browser stores on your computer or other device. You’ve probably got hundreds of them, several from each website you visit.
They enable websites to recognise you when you return and as you move around from page to page in their site. They might hold information such as a unique id, your name, when you last visited, how far you got through a process, what information you are interested in. They enable much of the magic of the web (they used to be called magic cookies). Importantly, they can do your computer no harm.
5.2 Why are we telling you all this? Because it’s the law. Since May 26th 2012, it is a legal requirement that all online service providers get consent for all but a few uses of cookies. This is intended to put web users in control of where their data is shared or used for targeting. You’ll be seeing a lot of this on the web. Find out more about the EU Privacy Directive and cookies from the ICO.
a) Sharing Tools: We would like to draw your attention to the fact that our site carries embedded ‘share’ buttons to enable users of the site to easily share articles with their friends through a number of popular social networks. These sites may set a cookie when you are also logged in to their service. Snazaroo does not control the dissemination of these cookies and you should check the relevant third party website for more information about these.
b) Analytics: The Snazaroo site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of our site and compile reports for us on activity on our site.
Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using our site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
How to reject or delete this cookie: http://www.google.com/intl/en/privacypolicy.html
5.4 What if you don’t want them? Honestly – they pose no threat to you – but if you really don’t want them you can turn off cookies in your browser (this will prevent all cookies from all sites).
6. How do we use your personal data?
6.1 We use your PII to provide our services (e.g., send service messages, process payments and/or fulfill orders).
6.2 We use your PII to help us communicate with you effectively should you try to contact us via our site including verification of any claims you may make.
6.3 If you have agreed on our site, we may use your PII to send you emails (or other communications) with details of our or third party goods or services which may be of interest to you including information about special offers or promotions.
6.5 We retain PII and other personal data from closed accounts in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted or required by law.
6.6 We may access, remove, alter or store or otherwise use any personal data (even PII) if we think you have or may have breached our terms and conditions or to enforce our rights or protect the public or where if we are required to do so by law or appropriate authority.
6.7 We will retain your personal data as long as is reasonably necessary to complete our dealings with you, or as may be required by law, whichever is longer.
7. How do we protect personal data?
7.1 Security is a high priority. We take appropriate precautions to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information.
7.2 Don’t forget that email and other electronic communications are not secure if they haven’t been encrypted. Your communications may pass through servers in a number of countries before they reach us. So we don’t accept responsibility for any unauthorised access to or loss of personal data that stems from a cause beyond our control. Nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your personal data which they collect from the site.
8. To whom do we disclose personal data?
8.2 We may allow access to your personal data by third parties who supply us with a service - for the purpose of their service only and in accordance with our instructions. Examples include couriers (to enable delivery of goods), website hosts and businesses which assist us in undertaking communications or monitoring our site.
8.3 As noted above, third-party advertisers may have access to certain personal data via persistent cookies and other similar technologies used in advertisements placed on our site.
8.4 All Content that you upload to our site including photos and associated information, such as geotags, may be available to and searchable by users of our site.
8.5 We may provide your PII to other companies within our group (the “Group”) so that they can send you emails (or other communications) with details of goods or services which may be of interest to you including information about special offers or promotions.
8.6 We may disclose personal data, including PII, so far as reasonably necessary:
a) if we think you have or may have breached our terms and conditions or to enforce our rights or protect the public or where we have reasonable grounds for believing that a criminal act has been committed or if we are required to do so by law or appropriate authority;
b) when we are legally required to do so pursuant to a subpoena or other legal process or court order;
c) in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business; or
d) if our assets are subject to a claim in bankruptcy, as such data may be an asset subject to the claims of a trustee in bankruptcy and may be available to our creditors.
By using the Site, you acknowledge and consent that we may store or transfer personal data outside the European Economic Area ("EEA") for the purposes stated in this policy, and that data protection laws may not afford the same level of protection as those of the country in which you are located (this is the case for users located in the EEA).
8.8 Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to third parties, whether they are other users of our site or other websites, different rules may apply to their use or disclosure of your information.
9. Privacy Protections for Children Using the Internet
Protecting children's privacy is important to us. For that reason, we do not collect or maintain information on our site from those we actually know are under the age of 13, nor is any part of our Web Site targeted to attract anyone under 13. We request that all visitors to our Web Site who are under 13 not disclose or provide any personally identifiable information. If we discover that a child under 13 has provided us with personally identifiable information, we will delete that child's personally identifiable information from our records upon notification and request from you.
10. How can you access and rectify personal data?
10.1 You can access and rectify your personal data by contacting us by the means shown on our website. We may charge an administration fee in line with data protection laws in your jurisdiction.
10.2 You should be aware that it may not be technologically possible to remove or verify each and every record of information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your personal data (including PII) may exist in archived systems. However, promptly after receiving your request, all personal data stored in databases we actively use and other readily searchable media will be updated, corrected, changed, deleted or confirmed to you, as appropriate, as soon as reasonably practicable.
10.3 For information about your rights under UK data protection laws, see the website of the UK Information Commissioner.
Version March 2012