Privacy policy

WHATSONPIC PRIVACY POLICY

Last modified on November 23th, 2018

The present document is the Privacy Policy for WhatsOnPic.com, an innovative platform that allows people to make immediate purchases of products they see in photos on social media sites. The platform includes the website located at www.whatsonpic.com (“WhatsOnPic Site”), WhatsOnPic mobile app (available in Apple Store) (“WhatsOnPic App”) and all other related applications and services (collectively “WhatsOnPic”).

The present Privacy Policy constitutes an integral part of the Terms and Conditions for WhatsOnPic.

WhatsOnPic respects your privacy and is committed to protecting your personal data. The aim of this Privacy Policy is to give you information on how WhatsOnPic collects and processes your personal data.

This Policy will also inform you of what we do with personal data, how we look after personal data and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

We collect the Personal Data from the Users as it is specified in the present Privacy Policy.

If you do not agree to your Personal Data being used in accordance with this Privacy Policy, please do not submit your Personal Data to us through WhatsOnPic or any other means.

Age Limits

WhatsOnPic is not intended for people under 18 years of age. We do not deliberately collect personal information from children under 18. If you are under 18, please do not provide any information on WhatsOnPic.

Foreign Users

Users from all around the world can use the WhatsOnPic App. However, WhatsOnPic is operated by us and is subject to the legislation of the Russian Federation. All information is processed, used and stored by WhatsOnPic within the Russian Federation. If you submit your personal information to us from another country, you agree to transfer it to the Russian Federation. Please check whether the legislation of your country allows to provide your personal information to foreign databases. We assume no liability to you or to any other person for your acts of non-compliance with your domestic legislation.

Data Controller (Owner)

LASKVILLE LLC (“LASKVILLE”, “we”, “us”), a legal entity duly incorporated in accordance with the legislation of the Russian Federation.

Owner contact email: admin@whatsonpic.com

Definitions

Personal Data (or Data) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier of that natural person.

Usage Data means information collected automatically through WhatsOnPic (or third-party services employed in WhatsOnPic), which can include: the IP addresses or domain names of the computers utilized by the Users who use WhatsOnPic, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within WhatsOnPic) and the details about the path followed within WhatsOnPic with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User means an individual using WhatsOnPic who, unless otherwise specified, coincides with the Data Subject.

Data Subject means a natural person to whom the Personal Data refers.

Data Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller, as described in this Privacy Policy.

Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of WhatsOnPic. The Data Controller, unless otherwise specified, is the Owner of WhatsOnPic.

Processing 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.

Third party means a natural or legal person, public authority, agency or body other than the Data Subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorized to process Personal Data.

Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her.

Cookies mean small piece of data stored in the User's device.

Notice to California residents

According to California Civil Code Section 1798.83, if a business has an established business relationship with a customer and has within the immediately preceding calendar year disclosed personal information that corresponds to any of the categories of personal information set forth in the Code to third parties, and if the business knows or reasonably should know that the third parties used the personal information for the third parties' direct marketing purposes, that business shall, after the receipt of a written or electronic mail request, or, if the business chooses to receive requests by toll-free telephone or facsimile numbers, a telephone or facsimile request from the customer, provide all the information about such a disclosure to the customer free of charge.

We hereby confirm that we do not disclose your personal information to a third party for that third party’s direct marketing purposes.

Types of Data collected

WhatsOnPic collects, by itself or through third parties, the following Personal Data:

- email address,

- password,

- Cookies,

- Usage Data,

- first name,

- username,

- last name,

- gender,

- country,

- PayPal account,

- picture.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using WhatsOnPic.

Unless specified otherwise, all Data requested by WhatsOnPic is mandatory and failure to provide this Data may make it impossible for WhatsOnPic to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are solely responsible for any third party Personal Data obtained, published or shared through WhatsOnPic and confirm that they have the third party's consent to provide the Data to the Owner.

IMPORTANT NOTICE: WhatsOnPic does not collect any credit card information. When you are redirected to the website of a shop, you provide all information to the owner of the shop website and not to WhatsOnPic. The only financial information WhatsOnPic collects about its Users is the PayPal account. We need it to pay affiliate rewards to our Users.

How the Data is collected

We use different methods to collect the Data from and about you including through:

• Direct interactions. You may give us your Personal Data as described in this policy by registering, filling in forms or by corresponding with us by post, phone, email or otherwise.

It is important that the Personal Data you provided us is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

• Automated technologies or interactions. As you interact with WhatsOnPic, we may automatically collect Usage Data.

Purposes of the Processing

We process your Personal Data for the following purposes:

1) to provide WhatsOnPic Services, namely: Registration and authentication, Analytics, Social features, Commercial affiliation, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with external social networks and platforms and Interaction with support and feedback platforms;

2) to contact you with information, notices, special offers and other information we believe will be of interest to you. Please take into account that when you create WhatsOnPic account, your email address will automatically be added to our emailing lists.

3) to improve the content, functionality and usability of WhatsOnPic, to better understand your needs and interests;

4) for security or fraud prevention purposes; and

5) for any other purpose identified in an applicable agreement between you and us upon your prior Consent.

Mode and place of processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

Processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of WhatsOnPic (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;

• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• processing is necessary for compliance with a legal obligation to which the Owner is subject;

• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating office in the US and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Detailed information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy PolicyOpt Out

MixPanel (MixPanel)

MixPanel is an analytics service provided by Mixpanel Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy PolicyOpt Out

 

Commercial affiliation

This type of services allows WhatsOnPic to display advertisements for third party products or services and links to the online shops where the products tagged on the pictures can be purchased.

IMPORTANT NOTICE: when you click on a third party advertisement or link to a third party website, you are redirected to a corresponding website. These websites and services have their own privacy policy. We do not bear any responsibility for third party websites and/ or services, links to which are represented on WhatsOnPic.

Ads can be displayed either as advertising links or as banners using various kinds of graphics.

Clicks on the icon or banner posted on WhatsOnPic are tracked by the third party services listed below, and are shared with WhatsOnPic.

For details of which data are collected, please refer to the privacy policy of each service.

Skimlinks (Skimbit Ltd)

Skimlinks is a commercial affiliation service provided by Skimbit Ltd.

Personal Data collected: Cookies and Usage Data.

Place of processing: UK – Privacy Policy.

VigLink (VigLink, Inc.)

VigLink is a commercial affiliation service provided by VigLink, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Hosting and backend infrastructure

This type of services has the purpose of hosting data and files that enable WhatsOnPic to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of WhatsOnPic. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon)

Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See the Amazon privacy policy – Privacy Policy.

Infrastructure monitoring

This type of services allows WhatsOnPic to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

New Relic (New Relic)

New Relic is a monitoring service provided by New Relic Inc.

The way New Relic is integrated means that it filters all traffic of this Application, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Application to be collected.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

 

Interaction with external social networks and platforms

This type of services allow interaction with social networks or other external platforms directly from the pages of WhatsOnPic.

The interaction and information obtained through WhatsOnPic are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Twitter Tweet button and social widgets (Twitter)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Pinterest “Pin it” button and social widgets (Pinterest)

The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Instagram Like button (Instagram)

The Instagram Like button is a service allowing interaction with the Instagram social network provided by Instagram Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – Privacy Policy.

Cookies

We use first-party cookies on WhatsOnPic to personalize your experience with WhatsOnPic, to understand and save your preferences for future visits, and to carry out other tasks relating to the operation or improvement of WhatsOnPic.

We do not use cookies to access information on your device.

All recent versions of popular browsers allow users to control cookies. Users can set their browsers to either accept or reject all or certain cookies. Users can also set their browser to notify them each time a cookie is offered.

Users can also control Local Shared Objects on their computer, also known as LSOs or Flash cookies, but not with their browsers. For example, Adobe's website offers tools to control Flash cookies on your computer. Users of the Firefox browser can also get an add-on to detect and delete Flash cookies. Please note that Flash cookies and HTML cookies are different in terms of deleting and removal. For more information about Flash cookies, please visit: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html, http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.

Direct registration

The User registers by filling out the registration form and providing the Personal Data directly to WhatsOnPic.

Personal Data collected: full name, email address and password.

Facebook Authentication (Facebook, Inc.)

Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

Personal Data collected: Facebook Public User profile.

Place of processing: US – Privacy Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

• Access their Data. Users have the right to learn if the Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this Privacy Policy, WhatsOnPic may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, WhatsOnPic and any third party services may collect files that record interaction with WhatsOnPic (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

WhatsOnPic Do Not Track notice

Please take into account that some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (DNT) or similar feature that can send a signal to websites that a user does not want to have his/her online activity and behavior tracked. If a website responds to a web browser’s DNT signal, the browser can block that website from collecting certain information about a user. Because of the changing state of technology and
indecision within the industry regarding the meaning of DNT signals, we inform you that WhatsOnPic does not respond to Do Not Track (DNT) signals.

Changes to this Privacy Policy

The Owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Contact Information

To ask any questions or provide comments about the present Policy and our privacy practices, please do not hesitate to contact us via email at:

support@whatsonpic.com

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