We are committed to protecting and respecting your privacy. This policy together with our Terms and Conditions sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us and you.
The data controller of your personal data is Tinto App Limited with registered office at 11 Broadway, SW1H OAZ.
INFORMATION WE COLLECT FROM YOU
Information you give us.
Activation of your Account on the App or by corresponding with us via the chat functionality within the App, or via video calls. You may also provide us with information when you register to use the App or report a problem with the App. We ask you to disclose only as much information as is necessary to provide you with our services through the App or to submit a question or comment in relation to the App.
When accessing the App as a user, the information required includes your name; email address; child’s or children’s date of birth; certain Special Category Personal Data.
Information we collect about you.
Technical information, including the Internet protocol (IP) address used to connect your device to the Internet; your login details; browser type and version; time zone setting; browser plug-in types and versions; operating system and platform.
Information about your visit, including the dates and times you use the App; search for page response times; download errors; length of visits to certain pages; and page interaction information.
USES MADE OF THE INFORMATION
We use this information in the following ways:
- to carry out our obligations arising from any contracts entered into between you and us, for example, the terms which govern how we make the App available to you and/or provide our services to you.
- to match your Tinto profile with other likeminded users;
- to comply with any legal obligations to which we are subject;
- to market our services to you and to provide you with information about other applications or online services that we may offer which are similar to the Apps or the services we are supplying to you;
- to notify you about changes to the Apps or our services;
- to administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the App and to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep the App safe and secure; and
- to make suggestions and recommendations to you about our other applications or services that may interest.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We collect and process your personal data on the basis of different legal grounds, depending on the nature of the personal data being provided and the type of processing involved. The legal grounds for the processing of your personal data include:
That the processing is necessary for the performance of the Service;
That you have provided consent for the processing for one or more specified purposes, such as, for example, when you opt to receive marketing communications from us or where you consent to providing your location when using the App;
That the processing is necessary for compliance with a legal obligation to which we are subject, for example where we are required under local laws to retain certain business records;
The processing is necessary for the purposes of the legitimate interests which we pursue and which are not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data. An example of our reliance on this legal ground is where the processing of your information is necessary to protect the security of the Apps or where we share your personal data with our affiliates or with our third party service providers and suppliers, as outlined further below. Tinto will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.
Where it takes place, the legal basis for the processing of any Special Category Personal Data relating to your health is that it is necessary in order to comply with any legal obligations.
DISCLOSURES AND TRANSFERS OF YOUR INFORMATION
In order to provide you with our services through the App, we may share your personal data with selected third parties including:
our business partners, suppliers and sub-contractors in connection with our operations and for the purposes outlined above only. Examples of such suppliers include partners we use to market our Service, our cloud-based communications software provider; our CRM software provider, our cloud storage provider and our document management system provider;
analytics and search engine providers that assist us in the improvement and optimisation of the App;
if we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
if Tinto App Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about the App’s users will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and any other applicable agreements; or to protect our rights, property, or safety or that of our customers, or others.
Sharing your information with Tinto affiliated entities and websites
For the purposes of this Policy, “affiliates” means any entity that directly or indirectly, controls, is controlled by, or is under common control of or with a Tinto entity, now or in the future. “Control” for these purposes means having a majority of shares or the right and ability to direct management. And this includes Tinto affiliated entities located outside the European Economic Area (“EEA”) or Switzerland.
Transfers of personal data outside of the EEA
We rely on a combination of legal mechanisms to support transfers of personal data outside of the EEA, which may include, where appropriate, the execution of Standard Contractual Clauses as approved by the European Commission to ensure that any personal data transferred is subject to appropriate safeguards; and/or transfers subject to the EU-US and Swiss-US Privacy Shield Framework certification in respect of transfers to Tinto affiliates or service providers in the US and other decisions from the European Commission that a third country provides an adequate level of protection.
STORAGE OF YOUR PERSONAL DATA
All information you provide to us is also stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
HOW LONG WE WILL RETAIN YOUR PERSONAL DATA
For further information on the periods for which we retain your personal information, please contact at email@example.com.
In order to optimise the performance of the App for our users, Tinto may perform automated processing of personal data including profiling in limited instances. If you are a user, this processing involves the App suggesting suitable engagements for you on our platform, on the basis of your personality profile, rating by other users, experience and motherhood stage.
Where it occurs, such processing is carried out where it is necessary for the performance of our agreement with our users and to allow Tinto to provide its Services to other users.
To contest any decision generated by automated means or to seek further information in this respect, please contact at firstname.lastname@example.org.
You have a number of rights in relation to how we process your personal data. These include:
- the right to access the personal data that we may hold about you;
- the right to rectify any inaccurate personal data that we may hold about you;
- the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to hold your personal data; where you object to your data being processed on certain grounds (for example, for marketing purposes) or where your personal data is being unlawfully processed;
- the right to ask us to provide your personal data in a portable format or, where technically feasible, to have your data ported to a new service provider if you no longer wish to use the Apps or our services;
- the right to request a restriction of the processing of your personal data; and
- the right to object to us processing your personal data including any processing for the purposes of direct marketing or profiling.
Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdraw your consent remains lawful. Where you are providing location information, you may turn off your location services on your device at any time.
You can exercise any of these rights any time by contacting us at email@example.com.
Should you have any concerns about how we handle your personal data, we encourage you to please contact us in the first instance. We will do our best to resolve your concern. You may also submit a complaint directly to your local supervisory authority with respect to our processing of your personal data. The supervisory authority in the UK is the Information Commissioner’s Office (ICO). For further details on how to complain to the ICO, please follow the links below: https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.
The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
If you have any queries you can contact us in writing at: Tinto App Limited, 11 Broadway, Westminster, London SW1H 0AZ, United Kingdom.
Or by emailing firstname.lastname@example.org