TABLE OF CONTENTS
1 KEY TERMS 2
2 INFORMATION WE COLLECT 3
3 WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU? 3
4 HOW AND WHY WE USE PERSONAL DATA? 4
5 MARKETING 5
6 WHO DO WE SHARE THIS PERSONAL DATA WITH? 6
7 ANONYMISED DATA 7
8 LEGAL GROUNDS 7
9 STORAGE AND RETENTION 8
10 SECURITY 8
11 DATA TRANSFERS 8
12 YOUR ELIGIBILITY 9
13 LAW PROVISIONS 9
14 COMPLAINTS 9
15 CONSENT 9
16 MODIFICATIONS TO THE PRIVACY POLICY 10
17 CONTACT US 10
PRIVACY POLICY
LAST UPDATED: Tuesday, September 5, 2023
We are delighted that you have shown interest in the services of CadTech Solutions Ltd. (“CTS”, “we”, “us”, or “our”) which are provided via our mobile application (the “StreetSmart App”). This Privacy Policy (this “Privacy Policy”) applies to any person (“User”, “you” or “your”) who engages with the StreetSmart App and by clicking a button or checking a box marked ‘I Agree’ has agreed to this Privacy Policy.
Your privacy is important to us, and we respect your privacy regarding any Personal Data that we collect when you register on the StreetSmart App or while availing the Services. We treat your Personal Data as confidential and in accordance with the statutory Data Protection Legislation and this Privacy Policy. This Privacy Policy covers how CTS handles your Personal Data when you are accessing and/or using the StreetSmart App and/or the Services.
You hereby acknowledge and admit that you have read, understood, and accepted to be bound by this Privacy Policy, as may be modified by CTS from time to time. Any amendments or variations thereto shall take effect from their date of publication on the StreetSmart App.
This Privacy Policy shall form a part of our Terms and Conditions published on the StreetSmart App. You agree to be bound by this Privacy Policy when you accept our Terms and Conditions. If there exists any contradiction between this Privacy Policy and the Terms and Conditions, this Privacy Policy will prevail.
Terms not defined in this Privacy Policy shall have the same meaning as that defined in the Terms and Conditions for Users published on the StreetSmart App.
1 KEY TERMS
In this Privacy Policy, (i) capitalized terms defined by inclusion in quotations and/or parenthesis have the meanings so ascribed; and (ii) the following terms have the meanings assigned to them herein below.
1.1 “Consent” means any freely given, specific, informed, and unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the Processing of Personal Data relating to them;
1.2 “Data Subject”, “you” and “your” collectively mean any identified or identifiable natural person, including Users, whose Personal Data is Processed by us. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
1.3 “Data Protection Legislation” means the Data Protection (Privacy of Personal Information) Act (DPA) and this Privacy Policy;
1.4 “Personal Data” means any information relating to a Data Subject; and
1.5 “Processing”, “Process” and “Processed” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
2 INFORMATION WE COLLECT
We collect information to provide better Services to all of our Users, including determining what types of Services are of the most interest and relevance to you.
2.1 Log Data: When you visit the StreetSmart App, our servers may automatically log the standard data provided by your web browser. It may include but not limited to, your computer’s internet protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and such other details.
2.2 Device Data: We may collect data about the device you use to access the StreetSmart App. This data may include but not limited to, the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
2.3 Personal Data: We may ask for Personal Data, including but not limited to name, e–mail ID, social media profiles, phone/mobile number, home/mailing address.
3 WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We collect Personal Data from you directly or via a third-party when you provide it to us directly and through your use of the StreetSmart App. This information may include:
3.1 information you provide to us when you sign up as a User to the StreetSmart App (e.g., your name, email address, phone number);
3.2 records of your interactions with us (e.g., if you contact our customer service team, interact with us on social media);
3.3 information you provide us when you enter a competition or participate in a survey;
3.4 information collected automatically, using cookies and other tracking technologies (e.g., which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access the StreetSmart App; and
3.5 other information necessary to provide the Services, for example we may access your location if you give us your consent.
4 HOW AND WHY WE USE PERSONAL DATA?
We only use your Personal Data if we have a proper reason for doing so, for example: Consent, contact, legitimate interests, or legal obligation.
4.1 Consent. Generally, we do not rely on Consent as a legal basis for Processing your Personal Data other than:
4.1.1 to place cookies and similar tracking technologies on your device including third-party cookies; and
4.1.2 when using your Personal Data for certain marketing purposes as per this Privacy Policy.
Where your permission is required, we will ask you for such Consent clearly and separately from the body of this Privacy Policy or our Terms and Conditions. You have the right to withdraw Consent at any time.
4.2 Contract. We will use your Personal Data if we need to do it to perform our obligations under a contract with you, or if it is necessary for a contract which we are about to enter with you, including but not limited to:
4.2.1 register you as a new User and administer your Account;
4.2.2 provide our Services to you; or
4.2.3 manage our relationship with you (e.g., to respond to your enquiries or to notify you about changes to the StreetSmart App and/or the Services).
4.3 Legitimate interests. We may Process your Personal Data when we (or a third- party) have a legitimate reason to use it, so long as this is not overridden by your own rights and interests, including but not limited to:
4.3.1 to administer and protect our business and the StreetSmart App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
4.3.2 to manage your Account and our relationship with you;
4.3.3 to interact with you professionally (e.g., if you represent our current or prospective customer, supplier, or business partner) to manage our relationship with the organization you represent;
4.3.4 to ask you to leave a review, give feedback or complete a survey;
4.3.5 for marketing purposes as per this Privacy Policy;
4.3.6 to increase our business or promote our brand through delivering relevant content, advertisements, and marketing communications to you;
4.3.7 to measure or understand the effectiveness of the advertising we provide to you; or
4.3.8 to improve the StreetSmart App, products, Services, marketing, and customer relationships; for the prevention and detection of fraud and spam; and for the establishment, exercise, or defense of our rights under our contract with you and/or legal claims.
4.4 Legal obligation. We may Process your Personal Data to comply with our legal obligation, including but not limited to:
4.4.1 notify you about changes to our Terms and Conditions or Privacy Policy;
4.4.2 address your complaint; or
4.4.3 comply with a request from a competent authority.
5 MARKETING
5.1 Depending upon your marketing preferences, we may use your Personal Data to send you marketing messages, newsletters, etc. by email or other contact information you provide to us. Some of these messages may be tailored to you, based on your previous browsing, and other information we hold about you.
5.2 If you no longer want to receive marketing communications from us (or would like to opt back in), you can change your preferences at any time by contacting us or by clicking on the ‘unsubscribe’ link in any email. If you unsubscribe from marketing communications, please note that we will keep a record of your email address to ensure we do not send you marketing emails in the future. We may still contact you with service messages from time to time, including but not limited to information about your legal rights.
5.3 You may also see ads for the StreetSmart App on third-party websites, including on social media. These ads may be tailored to you using cookies which track your web activity to enable us to serve ads to customers who have visited the StreetSmart App. Where you see an ad on social media, this may be because we have engaged the social network to show ads to our customers or Users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads, you can change your cookie and privacy settings on your browser and these third-party websites.
6 WHO DO WE SHARE THIS PERSONAL DATA WITH?
We may share your Personal Data with third-party for the purposes set out in this Privacy Policy.
6.1 Payment Processors
6.2 We may share your information with our payment processors for the purposes set out in this Privacy Policy.
6.3 We may share your Personal Data with payment gateways, to process payments in connection with providing our StreetSmart Services.
6.4 Our payment processors will, if necessary, pass on Personal Data to affiliates and service providers or subcontractors to the extent that is necessary to fulfil contractual obligations or for data to be Processed in the order.
6.5 The Data Subject has the possibility to revoke Consent for the handling of Personal Data at any time from the payment processor. A revocation shall not have any effect on Personal Data which must be Processed, used, or transmitted in accordance with (contractual) payment processing.
6.6 For information on how a payment processor uses Personal Data, please refer to their privacy policy.
6.7 Social Media
We may share your Personal Data with Facebook, Instagram, Google, and LinkedIn when you use the social media buttons embedded in the StreetSmart App.
6.8 IT and Technology
We may share your Personal Data with providers of other IT, digital, and technology products and services, which we use to operate our business. For example, providers of website hosting services, website and app analytics services, customer email services, digital marketing services, and social media advertising services. We impose contractual obligations on the above providers to ensure that your Personal Data is protected.
6.9 Other Sharing
We may also:
6.9.1 share your Personal Data with members of our staff, our subsidiaries, affiliates, and licensors;
6.9.2 disclose your Personal Data to professional advisers (e.g., lawyers, accountants, auditors, or insurers) who provide professional services to us;
6.9.3 disclose your Personal Data to certain third-party if specifically requested or agreed with you (e.g., if you ask us to introduce you to a third-party);
6.9.4 disclose and exchange certain Personal Data (where applicable) with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
6.9.5 share some Personal Data with other parties, such as potential buyers of some or all our business, potential investors, or group companies if our business undergoes a corporate re-structure.
Such data recipients will be bound by confidentiality obligations.
7 ANONYMISED DATA
We may also collect, use, analyze and share anonymized, aggregated data such as statistical or demographic data for any purpose including with the aim of increasing our data protection and data security and to achieve an optimal level of protection for the Personal Data we Process. The anonymized data of the server log files are stored separately from all Personal Data provided by a Data Subject. Anonymized data may be derived from your Personal Data but is not considered personal information in law as this information does not directly or indirectly reveal your identity.
8 LEGAL GROUNDS
8.1 We will Process your Personal Data lawfully, fairly and in a transparent manner. We collect and Process your Personal Data about you only where we have legal bases for doing so.
8.2 Where you Consent to our use of Personal Data for a specific purpose, you have the right to change your mind at any time without having any effect on any Processing that has already taken place.
8.3 We do not keep your Personal Data for longer than is necessary. When we retain your Personal Data, we will protect it as required under applicable laws to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. Notwithstanding the foregoing, we understand that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your Personal Data for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
8.4 We have implemented numerous technical and organizational measures to ensure the complete protection of Personal Data processed through the StreetSmart App. However, internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed.
9 STORAGE AND RETENTION
The criteria used to determine the period of storage of Personal Data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
10 SECURITY
10.1 We have appropriate security measures to prevent Personal Data from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it. Those Processing your Personal Data will do so only in an authorized manner and are subject to a duty of confidentiality.
10.2 Data Subjects shall be responsible for maintaining the confidentiality of their Account created on the StreetSmart App.
10.3 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10.4 The StreetSmart App ensures that Personal Data is encrypted when leaving the StreetSmart App. This process involves the converting of information or data into a code to prevent unauthorized access. The StreetSmart App follows this process and employs secure encryption methods such as SSL or TLS are utilized to protect customer data when in transit to and from the StreetSmart App over a secure communications channel. When SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
10.5 Whilst we do everything within our power to ensure that Personal Data is protected at all times on the StreetSmart App, we cannot guarantee the security and integrity of the information that has been transmitted to the StreetSmart App.
11 DATA TRANSFERS
Personal Data that we collect may be transferred to, stored at, and Processed by any of our affiliates, partners, or service providers in a location different from your country of residence as necessary to provide Services in accordance with the Terms and Conditions. By submitting your Personal Data, you agree to such transfers. Your Personal Data may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. We will ensure that such transfers are made in compliance with the requirements of the Data Protection Legislation.
12 YOUR ELIGIBILITY
12.1 By registering on the StreetSmart App, you represent that you are at least the age of eighteen (18) or the legal age in your jurisdiction of residence and are legally capable of making entering into a contract and using the credit card or other relevant payment details you submit.
12.2 The Data Subject must retain a copy of transaction records sent by email or other communication channels and merchant policies and rules.
13 LAW PROVISIONS
13.1 You have certain rights in respect of your Personal Data, including the right to access, portability, correct, and request the erasure of your personal data. The processing of your Personal Data shall always be in line with the Data Protection Legislation.
13.2 We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your Personal Data, or if you have any questions or concerns regarding your Personal Data, you should contact us by using the contact details set out in the ‘Contact Us’ section of this Privacy Policy. You are also entitled to contact your local supervisory authority for data protection. COMPLAINTS
13.3 We hope that we can resolve any query or concern you may raise about our use of your Personal Data. You may contact us by using the contact details set out in the ‘Contact Us’ section of this Privacy Policy.
13.4 This Privacy Policy also gives you a right to lodge a complaint with a supervisory authority, in the country where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in your respective area of residence may be contacted through the official mail address or contact number, or by post addressed to the concerned supervisory authority.
13.5 We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
14 CONSENT
14.1 When you provide us with Personal Data, you understand and agree that you Consent to our collecting it, and using is for that specific reason only.
14.2 If we ask for your Personal Data for a secondary reason, like marketing, we will either ask you directly for your expressed Consent, or provide you with an opportunity to say no.
14.3 Each Data Subject shall have the right to withdraw their Consent to the Processing of their Personal Data at any time. If the Data Subject wishes to exercise the right to withdraw their Consent, they may at any time directly contact us by using the contact details set out in the ‘Contact Us’ section of this Privacy Policy
15 MODIFICATIONS TO THE PRIVACY POLICY
15.1 CTS reserves the right, at its sole discretion, to modify this Privacy Policy anytime and without prior notice. If we modify this Privacy Policy, we will post the modification on the StreetSmart App or provide you with notice of the modification, to keep you informed of the information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. We will also update the ‘Last Updated Date’ at the top of this Privacy Policy. By continuing to access or use the StreetSmart App after we have posted a modification on the StreetSmart App, or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified terms of this Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the StreetSmart App and/or the Services.
15.2 If CTS is acquired or merged with another company, your Personal Data may be transferred to the new owners so that we may continue to provide services to you.
16 CONTACT US
If you have any questions, concerns, or suggestions about this Privacy Policy, you may contact us at info@streetsmart242.com.
You acknowledge that you have read, understood, and accepted to be bound by this Privacy Policy.
Effective as of March 17 2023.