1. IMPORTANT INFORMATION AND WHO WE ARE
CONTROLLER & CONTACT DETAILS
Full name of legal entity: Expper Technologies, Inc.
Name of DPO: Karen Khachikyan
Email address: [email protected]
Postal address: 2035 Sunset Lake Rd., Suite B-2, Newark, Delaware 19702
If you are subject to the GDPR and/or UK Data Protection Act 2018, you may also contact your local data protection authority within the European Economic Area for unresolved complaints (for example, the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk)). We would, however, appreciate the chance to deal with your concerns before you approach your local data protection authority so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). References herein to your personal data or personal data shall mean, as relevant, the personal data of Client Users, including children. We may collect, use, store and transfer different kinds of personal data about you and your Client Users, including children, that we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, and gender. Contact Data includes billing address, delivery address, email address, and telephone numbers. Sensory Data includes data and Content that Robin gathers through its interaction with you and Client Users, including children. Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. Usage Data includes information about how you use our Site, Robin, products, and the Services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
For the avoidance of doubt, Robin may collect only the following types of personal data from Client Users: Identity Data, Sensory Data, and Usage Data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not intentionally collect or store any kind of personal health information. Nor do we collect any information about criminal convictions and offences.
In the case of our other Services, we do not knowingly collect or solicit personal data from or direct or target interest-based advertising to anyone under the age of 13 or knowingly allow such persons to use or access the Services and/or the Site. If you are under 13, please do not send any data about yourself to us, including your name, address, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Robin and the Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including:
Directly from you when you provide it to us;
Automatically when you use Robin and/or the Services; and
Data we collect from our partners.
Information You Provide to Us
You or your Client Users, including children, may give us your or their Identity Data, Contact Data, Sensory Data, or Usage Data by filling in forms, corresponding with us, using Robin or the Services, or otherwise. You and your Client Users, including children, will share with us Content. The Sensory Data or Robin Content is not recorded or stored on our servers.
Automatic Information Collection and Tracking
When you register with, access, and use Robin and/or the Services, it may use technology to automatically collect:
Usage Data. When you access and use Robin and/or the Services, we may automatically collect certain details of your access to and use of Robin and the Services, including traffic data, usage data, location data, logs, and other communication data, Content, and the resources that you access and use on or through Robin and the Services; Technical Data. We may collect information about your Device and internet connection, including the Device’s unique device identifier, IP address, operating system, browser type, mobile network information, device (including operating system) language Location Information. Robin and the Services may collect real-time information about the location of Robin or your Device. For your Device, you can disable this function in the settings of your Device, but some parts of the Services may then not function properly.
You acknowledge and accept that Robin and the Services have certain content, features, functionality and/or services that are based on geolocation, location tracking, and geofencing which may also be collecting information on your use and access of Robin and the Services, including information on your surroundings and background. If you do not want us to collect this information, do not register with, use or access Robin and/or the Services. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).
Data We Collect From Our Partners
We also collect the following data from our partners: demographic data (such as to determine the coarse location of your IP address); data to fight fraud (such as refund abuse or click fraud); data from platforms that the Services run on (such as to verify payment); and data for analytics purposes, so we can provide you with better services.
Third-Party Information Collection
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: where we need to perform the contract we are about to enter into or have entered into with you; where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; where we need to comply with a legal obligation. We process your personal data for the following purposes:
To make Robin and the Services.
To perform the contract, we process data necessary to:
Create accounts and allow you to use Robin and the Services, access its contents, features, functionality, and services, and to access or use the Site; Operate our Services; Verify and confirm payments; At our discretion, provide and deliver products, services, and any other information you reasonably request; Send you Robin- or Services-related communications, such as when updates are available, and of changes to any products or services we offer or provide through Robin or the Services; Fulfill any other purpose for which you provide the information; Give you notices about your account; and Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To keep Robin and the Services safe and fair.
Analyze and monitor use of Robin and the Services and their social features; Moderate chats, forums, and other social interaction platforms either automatically or manually; Take action against fraudulent or misbehaving users.
To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile, and segment all collected data, including for the purpose of estimating our audience size and usage patterns.
With your consent.
With your consent, which is implied herein, we may process your data for additional purposes, such as personalized tips to improve your experience.
MARKETING & PROMOTIONAL OFFERS FROM US
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Sensory, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from or through us and you have not opted out of receiving that marketing.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. Except as explicitly provided hereunder, we do not sell your personal data. In addition, we may disclose personal information that we collect or you provide:
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, however, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through Robin and the Services. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures we provide.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We retain your data for as long as your account is active or you are otherwise accessing and using Robin and the Services or as needed to provide you with Robin or the Services. We will, for example, periodically de-identify unused accounts, and we regularly review and de-identify unnecessary data. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us the DPO at the contact information provided above.
No Fee Usually Required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need From You. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know.
Your Legal Rights. You have the right to:
Opt-out of marketing emails and other direct marketing. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: If you want us to establish the data’s accuracy. Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent, for example, by turning off GPS location sharing in your Device settings.