Provide name and contact details of the data controller. This will typically be your business or you, if you are a sole trader. Where applicable, you should include the identity and contact details of the controller’s representative and/or the data protection officer.
Specify the types of personal information you collect, eg names, addresses, user names, etc. You should include specific details on:
how you collect data (eg when a user registers, purchases or uses your services, completes a contact form, signs up to a newsletter, etc)
what specific data you collect through each of the data collection method
if you collect data from third parties, you must specify categories of data and source
if you process sensitive personal data or financial information, and how you handle this
You may want to provide the user with relevant definitions in relation to personal data and sensitive personal data.
Describe in detail all the service- and business-related purposes for which you will process data. For example, this may include things like:
personalisation of content, business information or user experience
account set up and administration
delivering marketing and events communication
carrying out polls and surveys
internal research and development purposes
providing goods and services
legal obligations (eg prevention of fraud)
meeting internal audit requirements
Please note this list is not exhaustive. You will need to record all purposes for which you process personal data.
Describe the relevant processing conditions contained within the GDPR. There are six possible legal grounds:
consent
contract
legitimate interests
vital interests
public task
legal obligation
Provide detailed information on all grounds that apply to your processing, and why. If you rely on consent, explain how individuals can withdraw and manage their consent. If you rely on legitimate interests, explain clearly what these are.
If you’re processing special category personal data, you will have to satisfy at least one of the six processing conditions, as well as additional requirements for processing under the GDPR. Provide information on all additional grounds that apply.
Explain that you will treat personal data confidentially and describe the circumstances when you might disclose or share it. Eg, when necessary to provide your services or conduct your business operations, as outlined in your purposes for processing. You should provide information on:
how you will share the data
what safeguards you will have in place
what parties you may share the data with and why
If applicable, explain if you intend to store and process data outside of the data subject’s home country. Outline the steps you will take to ensure the data is processed according to your privacy policy and the applicable law of the country where data is located.
If you transfer data outside the European Economic Area, outline the measures you will put in place to provide an appropriate level of data privacy protection. Eg contractual clauses, data transfer agreements, etc.
Describe your approach to data security and the technologies and procedures you use to protect personal information. For example, these may be measures:
to protect data against accidental loss
to prevent unauthorised access, use, destruction or disclosure
to ensure business continuity and disaster recovery
to restrict access to personal information
to conduct privacy impact assessments in accordance with the law and your business policies
to train staff and contractors on data security
to manage third party risks, through use of contracts and security reviews
Please note this list is not exhaustive. You should record all mechanisms you rely on to protect personal data. You should also state if your organisation adheres to certain accepted standards or regulatory requirements.
Provide specific information on the length of time you will keep the information for in relation to each processing purpose. The GDPR requires you to retain data for no longer than reasonably necessary. Include details of your data or records retention schedules, or link to additional resources where these are published.
If you cannot state a specific period, you need to set out the criteria you will apply to determine how long to keep the data for (eg local laws, contractual obligations, etc)
You should also outline how you securely dispose of data after you no longer need it.
Under the GDPR, you must respect the right of data subjects to access and control their personal data. In your privacy notice, you must outline their rights in respect of:
access to personal information
correction and deletion
withdrawal of consent (if processing data on condition of consent)
data portability
restriction of processing and objection
lodging a complaint with the Information Commissioner’s Office
You should explain how individuals can exercise their rights, and how you plan to respond to subject data requests. State if any relevant exemptions may apply and set out any identity verifications procedures you may rely on.
Include details of the circumstances where data subject rights may be limited, eg if fulfilling the data subject request may expose personal data about another person, or if you’re asked to delete data which you are required to keep by law.
Where you use profiling or other automated decision-making, you must disclose this in your privacy policy. In such cases, you must provide details on existence of any automated decision-making, together with information about the logic involved, and the likely significance and consequences of the processing of the individual.
Explain how data subject can get in touch if they have questions or concerns about your privacy practices, their personal information, or if they wish to file a complaint. Describe all ways in which they can contact you – eg online, by email or postal mail.
If applicable, you may also include information on:
You may include a link to further information, or describe within the policy if you intend to set and use cookies, tracking and similar technologies to store and manage user preferences on your website, advertise, enable content or otherwise analyse user and usage data. Provide information on what types of cookies and technologies you use, why you use them and how an individual can control and manage them.
Linking to other websites / third party content
If you link to external sites and resources from your website, be specific on whether this constitutes endorsement, and if you take any responsibility for the content (or information contained within) any linked website.
You may wish to consider adding other optional clauses to your privacy policy, depending on your business’ circumstances.
UGC Privacy Notice
Notice pursuant to art. 13 and 14 of EU Regulation 2016/679 on the protection of personal data (GDPR)
User Generated Contents
Pursuant to art. 13 and 14 of EU Regulation 2016/679 (hereinafter “GDPR”), dostaapka India. (hereinafter “Vasumu Services” or “Data Controller”) with registered office in PN 891/7C Faridabad Haryana India 121006, in its capacity of personal data controller, in the person of its legal representative pro tempore, informs you that the personal data of some of the physical persons of your employees and/or legal representatives and/or associates will be subject to processing on the part of dostaapka itself through manual processing or processing with electronic or automatic instruments, computers, or telematic instruments, strictly for the purposes listed below, and in any case in such a way as to guarantee the safety and confidentiality of the data.
Identity and contact details of the Data Controller and of the Data Protection Officer
The Data Controller is Vasumu Sevices India, in the person of its legal representative pro tempore, with registered office in PN 891/7C Faridabad Haryana India 121006.
The Data Controller has appointed a Data Protection Officer who you may contact in order to exercise your rights or obtain information regarding the same and/or this Notice by writing to Vasumu Services, Faridabad Haryana India 121006 or sending an email to info@dostaapka.com.
Categories of data obtained from subjects other than the Data Subject
For the purposes described in par. “Purposes and lawfulness of data processing”, dostaapka processes the categories of personal data, defined in par. “Retention period of personal data”, obtained directly from the Data Subject (art. 13) or from User who authorizes the Contents (art. 14).
Origin of personal data
Personal data is provided directly by the Data Subject (art. 13) or from User who authorizes the Contents (art. 14).
Purposes and lawfulness of data processing
Personal data is processed by the Data Controller pursuant to art. 6 of the GDPR.
The specific purposes of data processing and their legal basis are listed below:
Purpose of data processing
User Generated Contents
Legal basis of data processing
Performance of a contract or performance of pre-contractual measures (art. 6 par. 1, b) of GDPR)
Nature of data provision and consequences of refusal
Data provision is obligatory for the fulfillment of contractual obligations. Therefore, any refusal to provide the obligatory data will entail the objective inability to pursue the purposes of data processing outlined in this Notice (par. “Purposes and lawfulness of data processing”) and to conclude the contract.
Categories of recipients of the personal data
The personal data may be processed by Vasumu Services India as Data Processor specifically appointed by the Data Controller, pursuant to art. 28 of the GDPR.
The data will furthermore be processed by subjects specifically authorized by the Data Controller pursuant to the GDPR, such as employees of dostaapka following specific instructions given by the Data Controller.
The personal data processed by dostaapka may be subject to disclosure through publication on company social network pages (e.g. Instagram, Facebook, Twitter, Youtube) and websites.
Transfers to countries outside the EU
For the purposes data processing described above, personal data may be transferred to the subjects in the above categories in Italy or abroad, including outside the European Union (EU).
The company that provides the User Generated Contents service is based in the United States and stores the data in the Amazon Web Services. The Data Controller provides adequate guarantees (pursuant to art. 46 of the GDPR) through the adoption of the standard clauses relating to data protection adopted by the European Commission (Standard Contractual Clauses) with the Recipients of the personal data aforementioned, who process data both as Data Controllers and as Data Processors. These guarantees ensure compliance with data protection requirements and data subject rights adequate for processing within the Union, including the availability of the rights of data subjects, including administrative or judicial remedies and claims for compensation, in the Union or in a third country. To obtain a copy of your data, to get information about the adequate guarantees and to know the place where the data you provided have been made available, you can contact the Data Controller, at the following e-mail address: info@dostaapka.com
Retention period of personal data
Personal data processed by dostaapka will be retained for the time necessary for the performance of the contractual relationship. At the end of such limitations the personal data will be anonymized or deleted except in the case where conservation is necessary for other purposes expressly required by law.
The details concerning the duration of the data retention period for the purposes outline above, i.e. the criteria used for determining such periods, are listed below:
Purpose
User Generated Contents
Category of personal data
Identifiers: email address, IP Address, BV unique identifier, device fingerprint.
Additionally, in relation to Sampling only: name, postal address, telephone number.
Content data: Ratings given, review content (text/photo/video), questions, answers, nickname.
Demographic information: location, age range, gender, other client-specified demographics.
Behavioural data: including product interests, website browsing information, transaction data e.g. online purchases, website registrations.
Required limitation period before deletion
For the entire duration of the contract.
Automated decision-making
In the pursuit the purposes listed above, no decision will be made based only on automated processing that may cause any legal consequences for the Data Subject or that may similarly have a significant impact on their person.
Rights of the Data Subject
Pursuant to and in accordance with the GDPR, the Data Subject has the following rights that may be exercised towards dostaapka:
These rights may be exercised by contacting the Data Protection Officer (DPO) through a registered mail with return receipt sent to the following address: PN 891/7C Faridabad Haryana India 121006, or by sending an email to info@dostaapka.com.
The Data Subject may also inform the DPO through the means described above of any circumstances or events that may potentially cause a violation of their personal data (i.e. any violation of security that may accidentally or illicitly cause the destruction, loss, alteration, unauthorized disclosure, or access to the data), for the purpose of allowing an immediate assessment and, if necessary, taking preventative measures.
Please note that the Data Subject has the right to lodge a complaint to the Data Protection Authority or any other supervisory authority pursuant to art. 13, par. 2, letter d) of the GDPR.
