Splyt Privacy Policy

1. Our approach to privacy
1. Splyt Technologies Ltd ("Splyt", "we", "our", or "us") is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access and browse our website at splyt.com (the "Splyt Website") and information regarding our use of cookies and similar technologies.
2. Before accessing or using the Splyt Website, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.
2. Who is responsible for your personal information
1. Splyt is the data controller of the personal information we hold about you. This means that we determine and are responsible for how your personal information is used.
3. Personal information we collect about you and how we use it

Personal information you submit to us

1. We collect personal information that you submit directly to us, including information you provide when you fill in a form on the Splyt Website or communicate with us about our products and services.
2. We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.

3. The list below sets out the categories of personal information we collect about you, how we use that information and the lawful basis we rely on to process that personal information:

   Contact information, such as your name, email address and the name of your organisation. We use this information to communicate with you about our products and services and to respond to any queries, issues or concerns you have. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

   Comments and opinions. When you contact us directly, or when you fill in an online form, we will record your comments and opinions. We will use your comments and opinions to address your queries, issues and concerns and improve our products and services. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

Personal information we collect automatically

4. We also automatically collect personal information indirectly about how you access and use the Splyt Website and information about the device you use to access the Splyt Website:

   Information about how you access and use the Splyt Website. For example, the website from which you came and the website to which you are going when you leave the Splyt Website, how frequently you access the Splyt Website, the time you access our Splyt Website and how long you use it for, the approximate location that you access the Splyt Website from, and other actions you take on the Splyt Website.

   Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to access the Splyt Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Splyt Website through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

5. We may use the information we collect automatically to present the Splyt Website to you on your device and to determine products and services that may be of interest to you for marketing purposes. We may also use the personal information we collect from you to monitor and improve the Splyt Website and business, and to help us to develop new features on the Splyt Website.
6. The processing of the personal information we collect from you automatically is necessary for our legitimate interests, namely: to tailor the Splyt Website to the user and to improve the Splyt Website generally; to monitor and resolve issues; for marketing purposes; and for the detection and prevention of fraud.
7. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Splyt Website and developing new products and features. We may also share such anonymised information with others.
4. How long we keep your personal information
1. We will store the personal information we collect for our own purposes for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
5. Recipients
1. As required in accordance with how we use your personal information, we may share your personal information with the following:
1. Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
2. Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
3. Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Splyt, its users or others.
6. Cookies and similar technologies
1. The Splyt Website uses cookies and similar tracking technologies to distinguish you from other users of the Splyt Website. Cookies are pieces of code that we transfer to your computer's hard disk for record-keeping purposes. This helps us to provide certain functionalities of the Splyt Website, to monitor and improve the Splyt Website, as well as to allow our partners determine products and services that may be of interest to you and to display relevant advertising to you as you browse the Internet.
2. We use the following types of cookies:
1. Analytical/performance cookies. They allow us to recognise and count the number of visitors, to see how visitors move around the Splyt Website when they are using it and to monitor the performance of certain features on the Splyt Website. This helps us to improve the way the Splyt Website works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features.
2. Functionality cookies. These are used to recognise you as you move around the Splyt Website and to remember information that you enter when you use the Splyt Website, such as when you fill in a form.
3. The Annex contains more information about the cookies we use and how long they remain on your device.
4. If you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of the Splyt Website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
1. Cookie settings in Chrome web and Android
2. Cookie settings in Safari web and iOS.
3. Cookie settings in Firefox
4. Cookie settings in Edge
5. Cookie settings in Internet Explorer
5. If you only want to limit third party advertising cookies and similar technologies, you can opt out of receiving certain targeted advertising by visiting the following links (please bear in mind that there are many more companies listed on these sites than those that drop cookies via our website):
1. Your Online Choices (http://www.youronlinechoices.com)
2. Network Advertising Initiative (http://www.networkadvertising.org/)
3. Digital Advertising Alliance (http://www.aboutads.info/consumers)
7. Storing and transferring your personal information
1. Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers.
2. International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside of the EEA; these international transfers of your personal information will be made pursuant to appropriate safeguards, including:
1. ensuring that recipients or the country in which they are located are deemed by the European Commission to provide adequate protection for personal information; and
2. ensuring that transfers are subject to standard contractual clauses approved by the European Commission for the transfer of personal information.
3. We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.
4. If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy.
8. Your rights in respect of your personal information
1. In accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:
1. Right of access. You have the right to obtain:
1. confirmation of whether, and where, we are processing your personal information;
2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
3. information about the categories of recipients with whom we may share your personal information; and
4. a copy of the personal information we hold about you.
2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
2. You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.
4. You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
9. Links to third party sites

   The Splyt Website may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

10. Our policy towards children

    The Splyt Website is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

11. Changes to this policy

    We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

12. Notice to you

    If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Splyt Website.

13. Contacting us
1. Please contact us if you have any questions, comments and requests regarding this privacy policy.
2. This privacy policy was last modified on 11 June 2020.