Publication date: 7 of July 2022
1. General information
1.1 GoPractice Inc. is the data controller and is responsible for your Personal Data (collectively referred to as “Company”, “we”, “us” or “our”). Our full details are:
Postal address: 2261 Market Street #4830 San Francisco, CA 94114.
Email address: firstname.lastname@example.org
2. Information we collect
2.1. Registration and verification
2.1.1. When you register to use Platform by establishing an account, we will collect following personally identifiable information (“Personal Data”):
- Full name (patronymic name if applicable);
- Alias, username;
- Localization data: IP address, geolocation.
2.1.2. In order to keep your Personal Data accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page. Inaccurate information may affect your ability to use the Platform, the information You receive when using the Platform, and our ability to contact You.
2.2. When you use Platform
2.2.1. When you use Platform, we will collect following Personal Data:
- Account data: login name, password (for verifying you while singing-in), nickname, profile picture, e-mail, registration date and time.
- User generated content: any data submitted in calls, messages, chats, etc. by the Participant of his/her own choice. When You use the Platform, You may provide us with any text, images or videos that you upload or provide to us in the context. Content generated on or transmitted through the Platform, which may include audio, video, messages sent during your participation in the Test, content contained in chat exchanges, transcripts, written feedback, files, as well as related. Content may include your voice and image, depending on the account holder's preferences, your settings, including your preferences. Depending on the services and place of posting (chat room or forum), this information can be available to some or all other users of our services.
- Communications data. We may receive Personal Data when you send us an email message or otherwise contact us.
- Surveys. We may receive Personal Data when you provide information in response to a survey operated by us
- Third Party Sites. We may receive Personal Data when you access or log-in to a third--party site, e.g., Facebook, from our Platform. This may include the text and/or images of your Personal Data available from the third-party site.
- Submissions data: your feedback, comments, answers to questionnaires, opinions and other submissions with regard to our services form of texts, screenshots, audio or video recordings.
- Behavioral data: information about the way you use our services, its frequency and etc. (e.g., log-ins, services segments used, page views, transactions made within our services).
- Browsing data: your IP address, name of your browser, name of your Internet provider, traffic source (including the source from which our Platform was installed on your device).
2.3. We may require you to provide us with additional Personal Data as you use the Platform and the Website.
2.5. We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific software feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Policy.
2.6. We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health data).
3. How we acquire your data and what we use it for
3.1. Information may come from:
- You directly (from our communication and/or forms that you filled in);
- Cookies stored in your browser by our Website;
- Other sources including third parties and publicly available sources. When you connect third party services, apps or providers (such as Google Calendar) to our Platform, or when you register through a third-party account (such as Google or Microsoft), we receive Personal Data that includes your username, profile picture, email address, time, location, calendar information, contact information from such third parties and any information you choose to upload to such third-party services.
- Payment processor Stripe, PayPal.
3.2. We collect Personal Data for the following purposes:
|Processing purpose||Lawful basis for processing|
|Respond to your requests, for example to contact you about a question you submitted to our customer service team||Contract performance Consent|
|Inform you about changes in your services, our service offering and other important service-related notices;||Consent|
|Perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others||Consent|
|Comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings involving the Platform||Legal obligation|
|Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Platform and the Website, and for marketing and promotional purposes||Consent|
|Prevent and investigate fraudulent or other criminal activity||Legitimate interest|
4. How long we store your Personal Data
4.2. Please consider that we have the right to continue to retain some of your user data even after complying with your request to delete such data in the following cases:
- We have the lawful basis to further process your data other than a consent from you. We may be required to do so in order to comply with applicable laws (for example, for tax or accounting reasons, know-your-customer, anti-laundering or other legal requirements and obligations);
- Your user data has been anonymized in the way it cannot be used for identifying you, and therefore is no longer your personal identifiable data.
5.2. You should also be aware that we do not sell, rent your Personal Data or disclose it in exchange for money or other valuable consideration to any third parties and we shall not incorporate such practice in our business, unless providing you with a clear and explicit way to exercise your opt-out right and before introducing appropriate changes to this Policy.
5.4. We will display the Personal Data you select in your profile page and elsewhere on the Platform according to the preferences you select in your account settings. This Personal Data will be made available for public viewing to other users.
6. Marketing mailings
7. Transferring your data
7.1. Sharing Your data with third parties
|Category of recipient||Partner examples or explanation||Share purpose|
|Auditors, lawyer and other examination organizations||Any entity conducting audit or other legal/financial check||Compliance with our legal obligations imposed by applicable laws (in certain cases provided by law)|
|Payment partners||Stripe, PayPal||Enabling purchase opportunities within the Platform. These payment processors are responsible for the processing of your Personal Data, and may use your Personal Data for their own purposes in accordance with their privacy policies. More information is available here: https://stripe.com/gb/privacy|
|Data aggregation, analytics and market research services||Facebook Ads||Creating and utilizing analytics on our services and audience Conducting advertising and marketing activity Conduct surveys and research Personalizing our services for you|
|Advertising partners||Facebook Ads||Conducting advertising and marketing activity Personalizing our services for you|
|Relevant parties in the event of change in control, merger or acquisition||Facebook Ads||As our business develops, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.|
|Authorities and parties where relevant for compliance with various laws||Any authority||Compliance with our legal obligations imposed by applicable laws|
7.1.1. We require our services providers to agree to take reasonable steps to keep the Personal Data that we provide to them secure. We do not authorize them to use or disclose your Personal Data except in connection with providing their services.
7.2. Third-Party Privacy Policies
7.2.1. Our Website may contain links to third-party websites and applications. Subject to your opt-out preferences, we may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements on our Website.
7.2.3. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.
7.3. International transfers
We operate all over the world, and therefore we may transfer your data to our counterparties (partners, affiliates and etc.) in different countries, including those which are located outside the European Economic Area (EEA). We do all our efforts, including those imposed on us by applicable law, to ensure an adequate level of personal data protection in each case, HOWEVER, we would like you to consider that the countries to which we transfer your data may not have the same data protection laws as your jurisdiction.
To facilitate our global operations, the Company may transfer, store and process your operations with our partners and service providers based outside of the country in which you are based. Laws in those countries may differ from the laws applicable to your country of residence. Where we transfer, store and process your Personal Information outside of the EEA or the UK we will ensure that the appropriate safeguards are in place to ensure an adequate level of protection such as through acceding to the Standard Contractual Clauses. Further details regarding the relevant safeguards can be obtained from us on request.
Therefore, by using the Platform or submitting Personal Data for any of the above purposes, you acknowledge that your Personal Data may be transferred or may be stored in the United States of America or other countries outside of the EEA, and the United Kingdom. Such countries may have data protection rules that differ from or are less stringent than those of your country.
8. Your legal rights
8.1. General rights
|Your right||Right explanation|
|Right to access||You have the right to request the copy of your Personal Data processed by the Company|
|Right to rectification||You have the right to request that we correct any information you believe is inaccurate, incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing|
|Right to restrict processing||You have the right to restrict the use of your Personal Data in certain circumstances entirely or in part where possible, unless we have an opposite obligation required by applicable law|
|Right to erasure (“right to be forgotten”)||You can request the Company to erase any of your data unless we have an opposite obligation required by applicable law|
|Right to portability||You have the right to receive your data in a structured, commonly used and machine-readable format or to request the Company to directly transmit those data to a third party where technical possible and reasonable|
|Right to object to processing||You have the right to object to the processing of your Personal Data|
|Right to lodge a complaint with a supervisory authority||You have the right to complain to the data protection supervisory authority if You suspect that your data has been processed unlawfully.|
8.2. How to exercises your data protection rights:
8.2.1. In order to exercise your data processing rights stated, you shall send us a request via our support service: email@example.com, and follow the instructions provided or send us such a request directly or sent to firstname.lastname@example.org.
8.2.2. Please note that in some cases, in order to comply with a request, we may ask you to provide us with some additional information where this is necessary to identify you as our user. We undertake to comply with your request free of additional charge within one month of receipt, but in some cases this period may be extended by a further two months. We have the right to refuse to comply with your request or charge a reasonable fee if your request is manifestly unfounded or excessive.
8.2.3. Please note that complying with your request to restrict processing or to erase your personal data may result in the deletion of your Platform Account, so please consider this when deciding to exercise these personal data rights.
8.2.4. We would like to draw your attention to the fact that some of the aforementioned rights may have some limitations in terms of their exercising due to obligations imposed on the Company by applicable laws. For instance, in some cases we have to archive your data and continue to store it for a certain period of time (which depends on the requirements set forth by applicable law) even after you requested full erasure of such data.
8.3. Privacy rights in California, USA (CCPA)
Under the California Consumer Privacy Protection Act (CCPA) of 2018, California residents may be entitled to the following:
8.3.1. Access to the categories and specific types of personal data the Company collects, the categories of sources from which personal data is collected, the business purpose(s) for collecting personal data, and the categories of third parties to whom the Company transfers personal data.
8.3.2. Deletion of personal data under certain circumstances.
8.3.3. We do not sell your personal data in the traditional sense of the term. However, like many companies, we do use advertising services that seek to tailor online advertising to your interests based on information collected through cookies and similar technologies about your online activities. This is called interest-based advertising. The statutory definition in the CCPA of "selling" is broad and can include interest-based advertising.
8.3.4. Under California’s “Shine the Light” law (CA Civil Code § 1798.83), California users who provide Personal Data in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2019. will receive information regarding 2018. sharing activities).
8.4. Children's Information
8.4.1. Another part of our priority is adding protection for children while using the Internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
8.4.2. The Website and Platform are not directed to children under the age of majority, as defined by applicable law in your country of residence.
8.4.3. Platform is not directed to children under thirteen (13) years of age and we do not knowingly collect Personal Data from children under the age of thirteen (13). If we discover that a child under thirteen (13) has provided us with Personal Data, we will promptly delete such Personal Data from our systems.
8.5. What is opt-out opportunity
8.5.1. If you wish to opt-out the processing of your data with regard to certain purposes, including the purposes of direct marketing, you should send us a request via our support service https://gopractice.io/sat/, and follow the instructions provided or send us such a request directly or sent to email@example.com. However, we would like you to consider that opting-out certain processing purposes may lead to impossibility of providing you our certain (or even all) services in part (or at all). We will take our best efforts to minimize such services limitations.
Opt-out opportunities for California and Nevada residents
Despite the Company did not sell your data in the last twelve (12) months, we would like to inform you that both California and Nevada state grant its residents the following opt-out rights:
8.5.3. California residents using our services have the right to opt out the disclosure of their personal data to third parties for direct marketing purposes. If you would like to exercise this right you should contacting us at: firstname.lastname@example.org.
8.5.4. Nevada residents using our Services have the right to opt out the sale of covered information for monetary consideration. “Sale” and “covered information” shall be defined according to Nevada laws.
8.5.5. For a list of the categories of personal data we have shared for commercial purposes during the last twelve (12) months, please contact us at: email@example.com.
9.1. Like any other website, the Website uses “cookies”. Cookies are small text files accepted and processed by device that you use to access our Website. They are used to store information including visitors' preferences, and the pages on the Website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.
9.2. For more general information on cookies, please read “What are Cookies”
9.3. The following types of cookies are used on the sites:
- Strictly necessary cookies / technical cookies: these cookies are required to run the Website and provide you with the services and may, among other, allow us to identify your hardware and software, including your browser type;
- Statistical / analytic cookies: these cookies enable us to recognise users, count the number of users and collect information such as your actions on the Website, including the web pages you visit and the content you retrieve;
- Performance cookies: these cookies collect information about how users interact on the Website, enabling us to identify errors and test new functionalities to improve its performance;
- Functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Website, for example by storing your preferences (e.g., language and location);
- (Third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal Data. These cookies are also used for statistical and research purposes.
9.4. The Platform only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
9.5. Personal information collected through cookies placed on your device may be transmitted to and accessed by us or the third parties referred to in this policy. The use of Personal Data outside the Platform for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. The Platform or those third parties might also provide you with a possibility to opt out of personalized advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
9.7. The Platform may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
- To track your actions on the Sites and when using the Platform, by accessing and interacting with the cookies stored on your computer;
- To collect statistical information related to operating the Sites, the Platform or products, utilities, advertisements or other offerings.
10. How we secure your data
10.2. Please consider that we maintain some of our servers, where we store your data, and the databases containing your data outside the European Economic Area, and most likely, outside the country of your residence.
11.2. Compliance with applicable legislation. We are committed to complying with applicable privacy and data protection laws and regulations designed to protect your personal information, including, but not limited to Regulation (EU) 2016/679. of the European Parliament and of the Council of 27 April 2016. (GDPR) and other applicable current or future regional and state privacy and data protection laws and regulations worldwide as they become effective.
12. Questions, problems or complaints
Contact us if you have any questions, problems, or complaints regarding this Policy: firstname.lastname@example.org.