DOWN

Summary of Changes to Privacy Policy

Last Updated: June 8, 2018

  • In an effort to become more transparent with how we collect, use and transfer your private data, we have revised our Privacy Policy so that it explains in clear and concise detail the data we receive from you, how we collect and transfer it, and all of your rights and obligations with respect thereto. Below you will find a brief summary of the major updates.

  • Who Is Controlling Your Data?

    Section 1 of the Privacy Policy has been revised to clarify that Down is the only entity that functions as a controller of your data, regardless of where you are located.

  • What Data Do We Collect, How Do We Use It, and Whom Do We Share It With?

    Section 2 of the Privacy Policy has been revised to clarify that we only collect the minimum data necessary from you to provide our services – this may include contact information (such as your full legal name, physical address, email address, phone number), company name, job title, payment and/or billing information (including your credit card number and billing address), as well as certain personal data from your Facebook profile if you authorize us to (including your name, email address, birthday, work history, education history, current city, pictures stored on Facebook, and the names, profile pictures, relationship status, and information about your Facebook friends). In order to properly provide our services, we must collect what is classified as “special categories” of personal data under applicable law, such as your race, ethnicity, religion, philosophical or political views, and information relating to your sex life or sexual orientation. When you do use our services, and communicate with a user you match with, we will have to receive content on your behalf to be processed and sent to the other user. We also collect data from you when you communicate with Down so we can provide you with excellent customer service, as well as data relating to the usage statistics of our services through the use of cookies and tracking technologies built in to your browser to help improve the services. We also collect certain personal data from you when you authorize us to access your Facebook profile. If you refer a friend, then we will also have the name and contact information of that individual. Part of the data automatically collected includes data from your device and network.

    Section 3 of the Privacy Policy has been revised to clarify that we use your data to help provide the services to you, to further develop and personalize the services, to be able to match you with other users, to be able to communicate with you, to conduct surveys, market research, and to send you marketing communications. You have a right to opt-out of any marketing communications by clicking the link in the email to unsubscribe, by emailing us directly at feedback@downapp.com or by visiting https://downapp.com/manage-my-data.

    Section 4 of the Privacy Policy has been revised to clarify that we only share your private data with secure third-party partners, such as payment processors and technology providers (e.g., cloud computing services). We also share your data with our consultants, lawyers, accountants and other professional service providers, all of whom are either GDPR-compliant themselves or who have a duty to uphold the privacy of your data. Down may also share your data if required for legal purposes or with potential buyers of Down. Currently, we do not share your data with any marketers or advertisers, but may elect to do so in the future – if we do, you reserve the right to opt out of any such direct marketing by visiting https://downapp.com/manage-my-data.

  • How Long We Retain Your Data

    Section 5 of the Privacy Policy has been revised to clarify how long we retain any private data you provide to us. We maintain your personal data as long as you have an active user account. We can delete your user account upon request, but will still be required to maintain certain personal data to comply with legal obligations for a period of seven (7) years after removal of your account.

  • Your Rights Relating To The Use Of Your Data

    Section 6 of the Privacy Policy has been revised to clarify what rights you have regarding your personal data we hold. You can access, update and/or delete your personal data by vising your profile, emailing us or by visiting https://downapp.com/manage-my-data. You have many choices about how your data is collected, used and shared and we will help facilitate any of those choices you wish to pursue. Even if you delete your account, however, certain personal data may be kept for record retention purposes.

  • How We Secure Your Data

    Section 7 of our Privacy Policy has been revised to clarify how we secure your data. We implement secure socket layer (SSL) technology to encrypt your information. We monitor for and try to prevent security breaches.

  • Important Information For Individuals Located Within the European Economic Area

    Section 8 of our Privacy Policy has been revised to discuss the rights specific to individuals located within the European Economic Area (EEA), as well as to clarify our legal basis for processing your data. Countries in the EEA include EEA include Austria, Belgium, Bulgaria, Czech Republic, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom. You have a right to: (i) Requesting Explanations of What Data of Yours Down Stores and How It Is Used; (ii) request copies of your personal data; (iii) request your data to be deleted; (iv) file a complaint about the use of your data; or (v) request your data to be transferred. Our legal basis for collecting, using and sharing your data include consent, contract and legitimate interest. If the legal basis is consent, then you may withdraw your consent at any time. To exercise any of these rights, please email us at feedback@downapp.com or visit https://downapp.com/manage-my-data.

  • International Data Transfers

    Section 9 has been updated to clarify that if you are located outside of the United States, then your data is subject to international data transfers because all of our data is stored and processed in the United States. Any such international data transfers are performed in accordance with all applicable laws, including those set forth by the European Commission.

  • Cookie Policy

    Section 10 of our Privacy Policy has been revised to better explain our use of tracking technologies, such as cookies, that we use to help provide the services to you. If you wish to not utilize cookies, then you can opt out of such usages. However, if you do decide to opt out, then certain aspects of the services and/or their functionality may be limited or unusable.

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    This document was last updated on June 8, 2018