We will only use the personal data gathered through the Acorn as set out in this policy. Below you will find information on how we use your personal data, for which purposes your personal data is used, with whom it is shared and what control and information rights you may have.
1 Summary of our processing activities
Our Acorn solution is an age-friendly smart tablet and associated companion mobile application designed to enable those with limited digital technology skills to be fully empowered and engaged online. The following summary provides you with a quick overview of the processing activities that are undertaken on personal data when providing these services. You will find more detailed information under the indicated sections below.
- In case you register for one of our services, further personal data will be processed in the scope of such services (see III and IV).
- Your personal data may be disclosed to third parties (see IV) that might be located outside your country of residence; potentially, different data protection standards may apply (see V).
- We have implemented appropriate safeguards to secure your personal data (see VI) and retain your personal data only as long as necessary (see VII).
- Under the legislation applicable to you, you may be entitled to exercise certain rights with regard to the processing of your personal data (see VIII).
Personal data: is any information, relating to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
Processing: means any operation, which is performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or any kind of disclosure or other use.
3 Registration for our services
When registering the following categories of personal data are collected.
- Information (such as your first name, last name, address, date of birth, user name and email
address) that is provided by registration
- Information in connection with an account sign-in facility (e.g. username and password details)
- Communications sent by you (e.g. via e-mail or website communication forms)
We will process the personal data you provide to:
- Identify you at sign-in
- Provide you with the services and information offered through the service or which you request
- Provide localized services such as local news and events
- Administer your account
- Communicate with you
4 Usage of our Services : Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Date of Birth
- Phone number
- Address, Postal code, City
- Cookies and Usage Data
- Information regarding your usage may be collected (times of use, frequency of use of features and other statistics) and used to provide and improve the service.
- Error log data may also be stored on the device and uploaded. This log data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service.
Your personal data may be disclosed to third parties. We employ third-party companies and individuals due to the following reasons:
- To facilitate our Service;
- To provide the Service on our behalf;
- To perform Service-related services; or
- To assist us in analyzing how our Service is used.
5 Usage Data
We may also collect information that your browser or Acorn application sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
6 Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
7 Use of Data
Cliffrun Media Ltd. uses the collected data for various purposes:
- To provide and maintain the Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues
8 Transfer Of Data
Your information, including Personal Data, may be transferred to � and maintained on � computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Ireland and choose to provide information to us, please note that we transfer the data, including Personal Data, to Ireland and process it there.
9 Cross border data transfers
Within the scope of our information sharing activities set out above, your personal data may be transferred to other countries (including countries outside the EEA) which may have different data protection standards from your country of residence. Please note that data processed in a foreign country may be subject to foreign laws and accessible to foreign governments, courts, law enforcement, and regulatory agencies. However, we will endeavour to take reasonable measures to maintain an adequate level of data protection when sharing your personal data with such countries.
In the case of a transfer to a country outside of the EEA, this transfer is safeguarded by EU Standard Contractual Clauses. You can find further information about the aforementioned safeguards under: https://ec.europa.eu/info/law/law-topic/data-protection_en or by contacting the Data Protection Team at [email protected]
10 Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
11 Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
12 Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
We have reasonable state of the art security measures in place to protect against the loss, misuse and alteration of personal data under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal data. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit whilst it is in transit over the internet and any such submission is at your own risk.
Cliffrun Media Ltd. may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Cliffrun Media Ltd.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
14 Data retention
We strive to keep our processing activities with respect to your personal data as limited as possible. In the absence of specific retention periods set out in this policy, your personal data will be retained only for as long as we need it to fulfil the purpose for which we have collected it and, if applicable, as long as required by statutory retention requirements.
15 Your rights
Under the legislation applicable to you, you may be entitled to exercise some or all of the following rights:
- require (i) information as to whether your personal data is retained and (ii) access to and/or duplicates of your personal data retained, including the purposes of the processing, the categories of personal data concerned, and the data recipients as well as potential retention periods;
- request rectification, removal or restriction of your personal data, e.g. because (i) it is incomplete or inaccurate, (ii) it is no longer needed for the purposes for which it was collected, or (iii) the consent on which the processing was based has been withdrawn;
- refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time;
- object, on grounds relating to your particular situation, that your personal data shall be subject to a processing. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for an ongoing processing;
- take legal actions in relation to any potential breach of your rights regarding the processing of your personal data, as well as to lodge complaints before the competent data protection regulators;
- require (i) to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and (ii) to transmit those data to another controller without hindrance from our side; where technically feasible you shall have the right to have the personal data transmitted directly from us to another controller; and/or
- not to be subject to any automated decision making, including profiling (automatic decisions based on data processing by automatic means, for the purpose of assessing several personal aspects) which produce legal effects on you or affects you with similar significance. You may (i) exercise the rights referred to above or (ii) pose any questions or (iii) make any complaints regarding our data processing by contacting us using the contact details set out below
16 Contacting us
The information you provide when contacting us will be processed to handle your request and will be erased when your request is completed. Alternatively, we will restrict the processing of the respective information in accordance with statutory retention requirements.
17 Amendments to this policy