Effective: May 25th 2018
In this policy
“our”, “we”, “us” or “Putti” means APP LA CARTE LTD or any related APP LA CARTE Group company providing you with our services
“you” means you, the person using our services, or visiting our website
“services” means all goods or services we provide and anything else we do for you, including providing you with access to our website
2. GDPR Updates
A. Your rights under the GDPR
You have rights regarding your personal information, including the right to:
• access your information
• change or correct your information
• erase your information
• restrict our use of your personal information under certain circumstances
• obtain your personal information in portable form
• object to our use of your personal information under certain circumstances
• not be subject to profiling that has legal effects on you
B. What is your lawful basis for using my personal information?
There are a couple of reasons we believe we are allowed to collect, use, and store your personal information under the GDPR:
– 1. With your consent.
When you directly give us personal information for a certain purpose or otherwise express your consent, we can use that personal information for that certain purpose. You can withdraw your consent at any time. Please contact us if you would like to revoke your prior consent to any of these uses.
– 2. For our legitimate interests.
However, we do not always need your express consent to use your information. We can use your personal information as needed for our legitimate interests, so long as those interests do not conflict with your fundamental privacy rights and freedoms. These legitimate interests include:
• improving the presentation, operation, and experience of our services;
• evaluating and updating our technical infrastructure;
• monitoring and improving the information security of our websites.
– 3. By contract.
A contract also creates a basis for using your information. By accepting our Terms of Service, a contract is formed between us and you so that we may provide you our services. We can use your personal information as needed to provide our services to you under that contract.
– 4. Law, protection, or the public good.
We can also use your personal information to comply with our legal obligations, protect the vital interests of our users, and as needed for the public good. This may include using your personal information to prevent and handle potential fraud, security breaches or other prohibited activities.
EU’s General Data Protection Regulation (“GDPR”).
3. Information we collect
If you are just surfing and reading information on our website or applications, then we collect and store the following information about your visit:
The IP address of your machine when connected to the Internet and the domain name from which you are accessing the Internet
The operating system and the browser your computer uses, and any search engine you are using
Your browsing behaviour
Your online transactions
Your account activity
The date and time you are visiting
The URLs of the pages you visit
The domain name of the page you visit after leaving our website
If you are a Putti customer, Putti’s Terms and Conditions apply to your use of Putti services. Choose the Terms and Conditions that refer to the Putti service you use. The relevant Terms and Conditions set out our commitments to you regarding collecting, holding and using information about you.
4. How we use your information
We use your information to measure the number of visitors to different parts of the site and for a number of different purposes connected with the provision of services, for example, to measure the effectiveness of advertising.
Although we may publish aggregated information about usage patterns, we do not disclose information about individual machines or persons except for the reasons set out below in this section. We do not sell information which identifies you personally unless you specifically agree to it in the terms and condition of one of our services. We may gather more extensive information if we are concerned, for example, about security issues. If we think it is necessary, we can disclose information to relevant law enforcement authorities, such as the Police or the Department of Internal Affairs.
If you choose to provide us with personal information such as your email address, for example by filling out an electronic query or order form, we will use the information to communicate with you in relation to all the goods and services which we provide to you or which we consider might be of interest to you. This may include email marketing.
Personal information will be stored and used in accordance with our Terms and Conditions.
Our website places a cookie on the hard drive of your computer. A “cookie” is a file which allows us to track and target the interests of users. In addition, our website uses third party cookies from Google Analytics for Display Advertisers, including the following features:
Google Display Network Impression Reporting – which gives us additional insight into who has viewed our paid digital advertising on other websites. This will help us optimise and tailor our advertising.
DoubleClick Platform integrations & Remarketing with Google Analytics – the integrations between both our web analytics and paid advertising platforms together to give us additional insight. This allows us to tailor our advertising to ensure the right types and offers are shown to you while you are using the internet outside our website.
Google Analytics Demographics and Interest Reporting – which gives us insight into behaviour information relating to visitor age, gender and interests on an anonymous and aggregate level. This will help us to understand browsing behaviour to give you a better experience whilst visiting our sites.
Cookies are used to analyse your use of our website and to serve ads when you visit our website. The information we collect and share with third parties through cookies is aggregated and therefore anonymous (it does not include personal information which is likely to identify you). The information may be used to serve you ads in relation to our products when you visit our website and third-party websites.
While we recommend that users enable cookies on their browsers in order to enjoy all the features of our website, the decision remains in the hands of the individual. Most browsers allow you to control management of cookies, this will be different depending on each user’s PC – refer to your browser help menu for further information.
5. Access to your information and in addition to GDPR updates in policy
You have the right to access to personal information we hold about you where it is stored in such a way that it can be readily be retrieved. If the personal information we hold about you is not accurate or complete, then you may ask us to correct it.
To update your personal information, such as your billing address, you can contact us by email.
When signing in or shopping online, look for the ‘padlock’ symbol at the bottom of your web browser. The ‘padlock’ symbol is a certificate of authenticity and ensures the site is secure. You can double-click the padlock symbol to view the certificate’s details.
Secure Socket Layer (SSL) is the most accepted way of ensuring the security of transmitted information to and from Internet sites worldwide. On our site, it operates when you complete and send forms, but not while you are simply surfing the site.
7. Opting out
Turning off cookies
How do I unsubscribe from email marketing communications?
There are two ways to unsubscribe to any email message
Follow the unsubscribe instructions in the email
In writing using the contact details contained in the message
How do I file a complaint?
If you feel that your email address has been used without your permission and contacting the sender has not yielded satisfactory results you can issue a formal complaint by emailing us at firstname.lastname@example.org
8. Changing this policy
We may change this policy at any time by changing or removing existing terms or adding new ones. Changes may take the form of a completely new policy. We will tell you about any changes by posting an updated policy on our website. Any change we make applies from the date we post it on the website.