Privacy Policy



POST KULTURE PRIVACY POLICY

Last Updated: 1st June 2018

1.         INTRODUCTION AND GENERAL TERMS

These terms apply to Interactive Content Entertainment Ltd (“we”, “us”, “our” or “Post Kulture”). Interactive Content Entertainment Ltd is a company registered in England and Wales under company number 08618531. Our registered office is 38 Kingsland Road, Post Kulture office 4, Perseverance Works, London, E28, DD.  

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of our website (“Website”), digital app (“App”) or platform and any related online services (together, the “Services”).

If you have any questions or comments about this Privacy Policy, please contact us at data@postkulture.com

We are committed to protecting and respecting your privacy.  The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

§  What information we may collect about you;

§  How we will use information we collect about you;

§  Whether we will disclose your details to anyone else; and

§  Your choices and rights regarding the personal information you have provided to us.

The Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them.  They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services.  We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

If you do not agree to this policy, please do not use the Service. We may, from time to time, make changes to our policy and will update this page and, where appropriate, we will email you. Please check back frequently to see any updates or changes to this policy.

2.         INFORMATION WE MAY COLLECT ABOUT YOU

To provide our Services to you, we collect and process the following information which may include your personal data.

Information provided by you when using the Services

(“Basic Information”)

We may collect the following information from you:

·     Your user ID;

·     Contact details: name and email address (compulsory), gender, date of birth (optional), address;

·     IP address;

·     Facebook ID; and

·     Stripe ID (see below for Payment Processing)

Information collected for the purposes of providing analytics

(“Analytics”)

We may collect technical information about your use of the Services through the use of tracking technologies and analytics.

Personal data we may collect includes the following:

  • your Device ID;
  • your user ID;
  • your device operating system & version;
  • your device make and model;
  • browser and details of your visits use of Post Kulture;
  • the language and country of your Device ID;
  • pages and products viewed, searches made, page interaction and clicks; and
  • identification of crashes and defects.

We use a third party analytics provider called Google Analytics when conducting our analysis however we do not share any personal data with them.

If you would like to find out more about the way Google Analytics collects and processes this information this is set out in their privacy policy https://support.google.com/analytics/answer/6004245?hl=en.

You can always choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser. For further information about cookies, please see: www.allaboutcookies.org, and how to adjust your browser settings here: www.allaboutcookies.org/managecookies.

Information about you collected from third parties

(“Third Party Log In Information”)

When you access the Services via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, its URL, your Facebook ID, email address and gender information. We will also receive technical data in order to ensure the Services connect to the correct Facebook account.

Artist Exclusive purchase

(“Payment Processing”)

When you purchase an item directly from Post Kulture, we use a third party payment system called “Stripe” which transacts all our payments. We have no access to your card payment information. We only hold your address and email address and name on our records for delivery purposes.

If you would like to find out more about the way Google Analytics collects and processes this information this is set out in their privacy policy: https://stripe.com/gb/privacy.

 

You can use our Services, by creating an account, login via Facebook or as a Guest.

If you decide not to create an account with us, our platform will register you as a guest. This means the only data we can view are the number of items you have looked at. We will not know who you are, or what IP address this came from. Our data team will only be able to see what pages are viewed, where the traffic comes such as a desktop computer, or an IOS device and more review more general user behaviour on our platform. We will never be able to track down who you actually are.

 

3.         WHY WE COLLECT INFORMATION ABOUT YOU

To provide our Services to you

We will use information about you for delivering our Services to you under the terms of our services agreed between us.

This allows you to participate in the features of Post Kulture when you choose to do so. It also allows you to carry out transactions with our retail and payment partners through our service and third party websites.

To help us improve the Services and fix any problems

We may process information about you according to our legitimate interests so that we can analyse and improve our Services.

This processing is also necessary for us to (i) ensure that our Services function properly so that you and other users have the best experience when; (ii) improve the quality of our Services, and providing a better experience to our users; (iii) identify and correct any bugs in the Services and (iv) understanding the effectiveness of our marketing to attract new users and re-engage our current users.

To respond to your enquiries and requests for support

We may process contact information where necessary for the performance of a contract or where in our legitimate interest so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us.

To third parties

Except as set out in this policy, we do not disclose information about identifiable individuals to our retail partners or third parties, but we may provide them with aggregate information about our users (for example, we may inform them that 100 women aged under 25 have clicked on a particular product ). We may also use such aggregate information to help our retailer partners reach the kind of audience they want to target (for example, male following the trend “Supreme Hoodie”). We may make use of the personal data we have collected from you to enable us to comply with our retail partners' wishes by displaying their product to that target audience.

To acquire new users and engage current users

§  [We may process information (including some Analytics) to pursue our legitimate interest to encourage engagement from our less active users and to notify them with new items or other promotions on offer.][SS1] 

§  We may also process this information to pursue our legitimate interests of acquiring new users. 

§  We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.

Mailing List

If you ask to be added to our mailing list, we will keep you updated with information on [news and updates] unless you would like to be removed from that list (in which case please let us know by clicking unsubscribe at the bottom of any marketing email that you receive).

In line with the legitimate interest we have in promoting our business, we will use the email address you gave us via our Website to provide you with this information.

We use MailChimp to manage email marketing subscriber lists and send emails to our subscribers.

There may also be circumstances where we will ask you for your explicit consent in respect of our use of your data in which case you will be notified at the time.

To prevent fraud and illegal activity

We process personal data to comply with our legal obligations ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals and to enforce our legal rights.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

 

4.         DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Post Kulture, our customers, or others.

Third party mailing: We may process information about you with Mailchimp, which we use to manage email marketing subscriber lists and send emails to our subscribers. See their privacy policy at https://mailchimp.com/legal/privacy/.

Notifications: We may process your information with OneSignal, which we use to send you notifications. No personal data is shared except a unique identifier provided by the phone manufacturer. See their privacy policy at https://onesignal.com/privacy_policy.

 

5.         CONSUMER CONTROL AND OPT-OUT OPTIONS

[If you do not wish to continue to have an account with us or receive notifications from us you can opt-out by changing your advertising and notification settings on your device directly.][SS2] 

And if you want to close your account and request mysnapp to delete all of your personal information, please send an email to data@postkulture.com.

6.         YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below.  We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know by sending an email to data@postkulture.com.  

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

 

Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

§  you consented to our processing the personal data, and have withdrawn that consent;

§  we no longer need to process that personal data for the reason it was collected;

§  we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Post Kulture or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

§  the personal data was unlawfully processed;

§  you need the personal data to be deleted in order to comply with legal obligations;

§  the personal data is processed in relation to the offer of a service to a child.

 

Obtain a machine readable copy of your personal data, which you can use with another service provider

  • If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

§  If you request, we will supply you with the relevant personal data in. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

 

Make a complaint to a Supervisory Authority

  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
  • If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority: www.ico.org.uk

 

7.         Data Retention

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

8.         CHILDREN

We do not use our Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Services.  In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at data@postkulture.com.

9.         Security

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.  For example, our databases are limited to essential employees only.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

10.     INTERNATIONAL DATA TRANSFERS[SS3] 

Our information is generally stored within the EEA on secure databases.

Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data.  If you would like to find out more about these safeguards, please let us know by writing to data@postkulture.com.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to us at data@postkulture.com.  

 


 [SS1]Please confirm whether you do this.

 [SS2]Confirm you have this capability or you need to be contacted via email

 [SS3]Please note although you say you don’t transfer data outside EEA, however if you use for eg MailChimp it is likely you do. Please confirm.