PressPad sp. z o.o. (an LTD company, the “administrator” of the mobile app) respects the privacy of the app users (“End Users”) and complies with applicable laws for the protection of your privacy, including, without limitation, the European Union General Data Protection Regulation ("GDPR") and the Swiss and EU Privacy Shield Frameworks.
Wherever we talk about Personal Data below, we mean any information that can either itself identify you as an individual ("Personally Identifying Information") or that can be connected to you indirectly by linking it to Personally Identifying Information. PressPad also processes anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage patterns, and demographics of customers as a group or as individuals. Such anonymous data does not allow the identification of the customers to which it relates. PressPad may share anonymous data, aggregated or not, with third parties like the “app owner”.
2. Why PressPad Collects and Processes Data
PressPad collects and processes Personal Data for the following reasons:
- where it is necessary for the performance of our agreement with you to provide a full-featured digital service and deliver associated Content and Services;
- where it is necessary for compliance with legal obligations that we are subject to (e.g. our obligations to keep certain information under tax laws);
- where it is necessary for the purposes of the legitimate and legal interests of PressPad or a third party (e.g. the interests of our other customers and or the “app owner”), except where such interests are overridden by your prevailing legitimate interests and rights; or
- where you have given consent to it.
These reasons for collecting and processing Personal Data determine and limit what Personal Data we collect and how we use it (section 3. below), how long we store it (section 4. below), who has access to it (section 5. below) and what rights and other control mechanisms are available to you as a user (section 6. below).
3. What Data We Collect and Process
3.1 Basic Account Data
When installing the app, PressPad will create and collect your unique ID and your mobile device’s signatures like a brand name, model and operating system. The provision of this information is necessary to register and identify the “end user” Account. During setup of your account, the account is automatically assigned a number (the "User ID") that is later used to reference your user account without directly exposing Personally Identifying Information about you.
We do not require you to provide or use your real name for the setup of the app but in some cases you may be requested to provide your, a valid email address. You can always skip this request.
3.2 Transaction and Payment Data
In order to make a transaction in the app (e.g. to purchase access to the content or the other publication, (“in-app transaction”), you may need to provide at the first place payment data to the app store’s payments operator via their store’s app (e.g. App Store and/or Google Play and/or Amazon Appstore etc.) to enable the transaction. If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code) to Payments operator (not PressPad the “app administrator” nor the “app owner”), which will be processed and transmitted to the payment service provider (Payments operator) of your choice to enable the transaction and perform anti-fraud checks. Likewise, PressPad will receive only the transaction confirmation data from your payment service provider for the same reasons.
3.3 Other Data You Explicitly Submit
We will collect and process Personal Data whenever you explicitly provide it to us or send it as part of communication with others on PressPad platform, e.g. in PressPad web chats, or when you provide feedback or other user generated content including contact forms etc. This data includes:
- Information that you post, comment or follow in any of our Content and Services;
- Information sent through chat;
- Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant;
- Information you provide to us when responding to surveys, e.g. your contact details.
3.4 Your Use of the mobile app
We collect a variety of information through your general interaction with the app and it’s content. Personal Data we collect may include, but is not limited to, device information, data collected through automated electronic interactions and application usage data.
3.5 Your Use of the Content Subscriptions (Paid Access)
In order to provide you with services, we need to collect, store and use various information about your activity in the app we are administrating. "Content-Related Information" includes your User ID, as well as what is usually referred to as "platform statistics". By platform statistics we mean information about your reading preferences, progress in the content reading, reading time, as well as information about the device you are using, including what operating system you are using, device settings, unique device identifiers, and crash data.
3.6 Information Required to Detect Violations
We collect certain data that is required for our detection, investigation and prevention of fraud and other violations of this, and related agreements and applicable laws ("Violations"). This data is used only for the purposes of detection, investigation, prevention and, where applicable, acting on of such Violations and stored only for the minimum amount of time needed for this purpose. If the data indicates that a Violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such Violations.
4. How Long We Store Data
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for longer storage and retention period — for the storage and retention period required by law. As per your explicite request your anonymized Personal Data can be deleted as provided by applicable law.
5. Your Rights and Control Mechanisms
The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. While other jurisdictions may provide fewer statutory rights to their citizens, we make the tools designed to exercise such rights available to our customers worldwide.
To allow you to exercise your data protection rights in a simple way contact us at email@example.com
If you are a resident of the European Economic Area you have the following rights in relation to your Personal Data:
5.1 Right of Access.
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the Privacy Dashboard. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
5.2 Right to Rectification.
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided.
5.3. Right to Erasure.
You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion. For individual items of Personal Data please request the deletion via the app “Help button”.
As a result of deleting your reader’s ID, you will lose access to the particular app services, including the access to previously bought content, Subscriptions and publication(s) information linked to the User ID and the possibility to access other services you are using through any tied services.
5.4 Right to Object.
You also have the right to lodge a complaint at a supervisory authority.
The minimum age to use the app is explicite mentioned in the app’s page of the relevant “app store”. By default it is set to 13 years old. PressPad will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, PressPad requires parental consent before the mobile app can be installed and Personal Data associated with it collected. PressPad encourages parents to instruct their children to never give out personal information when online.
7. Contact Info
You can contact PressPad's at the address below: firstname.lastname@example.org
PressPad Sp. z o.o. Slusarska 9 str, 30-701 Krakow, Poland, EU