Updated June 2016
This Privacy Statement has been adopted by Setapp Limited, a company registered in Ireland with company number 584165 and registered office address of 9 Tallow Street, Youghal, Co. Cork, P36 YE14 ("Setapp", "We", "Us", "Our") in order to demonstrate our firm commitment to privacy.
- your use of this application or website and any and all other websites or applications provided by, operated by or available for download from Setapp and any of the services accessible or available through those applications or websites (together the "Sites"); and
- your use of any software or applications made available on the Sites ("Third Party Applications") from a third party App Developer or distributor ("App Developer"); provided, however, that there may be additional privacy statements applicable to Third Party Applications that govern the App Developer’s use of your personal data. You should review such additional privacy statements before using any Third Party Applications.
This Privacy Statement sets out the basis on which we gather and use any personal data we collect from you, or that you provide to us by using the Sites or Third Party Applications. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We will use your personal data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your personal data is in compliance with the Data Protection Acts 1988 and 2003 (the "Acts"). [For the purposes of the Acts, Setapp is the data controller in respect of your personal data made available on the Sites. However, to the extent that Setapp processes any personal data on behalf of an App Developer in making Third Party Applications available via the Sites or collecting payments in connection with them, the applicable App Developer shall be the data controller and Setapp will be the data processor in respect of such data. Please ensure that you have reviewed the terms of any privacy statements made available in connection with any Third Party Applications before you use those Third Party Applications.]
ACCEPTANCE OF THIS PRIVACY & COOKIE STATEMENT
We reserve the right to modify this Privacy Statement at any time. Any changes to this Privacy Statement will be posted on the Sites so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Your continued use of any portion of the Sites following notification or posting of such changes will constitute your acceptance of those changes.
WHAT PERSONAL DATA WE COLLECT
We may collect and process the following data about you:
When you place an order, we collect basic information such as your name, physical and email address, telephone number and other contact details. We may also obtain your credit card, payment and other related information.
You may also be asked to provide or may provide additional Personal Data in course of:
- Communicating with us about your order.
- Downloading and installing our software, applications and updates.
- Supplying feedback and information about your use of our products.
- Requesting us to stay in touch with you.
Information you give us:
You may give us information about you by filling in forms on the Sites, when you place an order, or by corresponding with us (for example, by e-mail or chat) or otherwise through your use of the Sites and/or any Third Party Applications. This includes information you provide when you register to use the Sites, download, install or register an application, any software and/or updates, subscribe to any of the Third Party Applications, search for applications, services or functions, supply us with feedback in relation to your use of the Site and/or any Third Party Applications and/or when you report a problem with the Sites or any of our Services.
The information you give us may include:
- Contact and billing information details such as your name, email address, postal address and phone number.
- Details of your visits to the Sites and/or any Third Party Applications and the resources that you access, including but not limited to, traffic data, location data and other communication data.
- Payment or financial account information (including credit card details).
- Details of your credentials such as passwords and other security and authentication data.
- A record of any correspondence, where you contact us.
- Information relating to comments, advices and content you may post on our Sites or in connection with the Sites and/or any Third Party Applications.
When you access the Sites and/or any Third Party Applications, your device provides us with information such as your IP address, browser type and access time. Collecting information in this manner allows us to collect statistics about the usage and effectiveness of Sites and/or any Third Party Applications, personalise your experience and tailor our interactions with you.
) or any other third party service provider as applicable.
Information about you from other sources:
We also work closely with third parties (including, for example, App Developers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
USE OF YOUR INFORMATION
We use information held about you in the following ways:
- To enable personal identification within the Sites and/or any Third Party Applications, to register you as a member on the Sites and/or any Third Party Applications, including to facilitate your access to and use of the Sites and/or any Third Party Applications.
- To provide you with general information on the Sites and/or any Third Party Applications.
- To provide you with access and use of the Third Party Applications.
- To respond to your requests for information, queries and other communication or correspondence you may submit to us.
- To ensure that content on the Sites and/or any Third Party Applications is presented in the most effective manner for you and for your device.
- To provide you with information or services that you request from us.
- To carry out our obligations arising from any contracts entered into between you and us and to enforce the terms of our Applicable Terms.
- To administer, or communicate with you about your membership to, or use of, the Sites.
- To allow you to participate in interactive features of the Sites and/or any Third Party Applications, when you choose to do so.
- To notify you about changes to the Sites, any Third Party Applications or policies;
- To communicate with you in general (including for example and without limitation, via email, telephone or SMS), including to provide information about the Sites and/or any Third Party Applications; and
- To gather management information to form statistical, modeling and trend analysis with the aim of developing and improving products and services.
We may also use your personal data, to provide you with information about goods or services which may be of interest to you and we may contact you about these by email where you have consented to be contacted for such purposes.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal data to any member of our
Group (which means our subsidiaries, our ultimate holding company and its subsidiaries, from time to time) and to our or their service providers, subcontractors, strategic partners that work with us to provide products and services, business partners and agents and/or any third party App Developers that make Third Applications available on the Sites to, or that help us market to customers (collectively “Contractors”). Such Contractors may include, without limitation, third parties who carry out hosting, cloud services, maintenance or provide us with other services, such as market research studies, in relation to the Sites and/or any Third Party Applications we provide to you. We share personal data with Contractors who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys.
We may also disclose your personal data to third parties (including third parties who are not Contractors):
- In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets;
- If any member of our Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets (for example, in the form of a database of users of the Sites);
- If We are under a duty to disclose or share your personal data in order to comply with any legal obligation or court order, or in order to enforce, establish, exercise or defend legal rights, the rights, property, or safety of you, us, our Group, or employees either within or outside your country of residence;
- For marketing purposes where we have your consent to do so in accordance with the Applicable Terms; or
- In order to enforce or apply the Applicable Terms and other agreements or to investigate potential breaches;
We may also provide non-personal data to third parties, where such information is combined with similar information of other users of our Sites.
LINKS TO OTHER WEBSITES
Our Site may contain links to and from the websites that belong to third parties. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy statements or policies and that we do not accept any responsibility or liability for these statements or policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Our Sites may also use or offer products or services from third parties (including Third Party Applications). Information collected by third parties, which may include such things as location data or contact details, is governed by the applicable privacy policies provided. We encourage you to read the privacy policies of all such third parties and App Developers.
WHERE WE STORE YOUR PERSONAL DATA
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), for the purposes described above. It may also be processed by staff operating outside the EEA who work for us or for one of our Group or our Contractors who act on our behalf. Such staff may be engaged in, among other things, the processing of your request for information, the provision of Services to you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Statement and the Acts.
SAFEGUARDING YOUR INFORMATION
The security and confidentiality of your personal data is extremely important to us. As no data and information transmission over the Internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information that you transmit to us and you transfer the personal data at your own risk. We endeavour to use and keep under review appropriate technical and organizational measures (including staff training and awareness) in order to protect against unauthorised or unlawful processing of your personal data, including unauthorised destruction, alteration or disclosure or access. We shall only hold personal data for as long as is necessary or as required by law.
You have a right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can also exercise the right to prevent such processing at any time by contacting us at the address set out in the "Contacting Us" section at the end of this Privacy Statement.
You have the right to request a copy of the personal data held by us about you. We may charge a fee for this which will not exceed €6.35 or such other amount otherwise permitted by law. You also have the right to access your personal data, have changed any inaccuracies in the details we hold about you, the right to object to the use of your personal data in certain circumstances and the right to block any specific uses of your personal data.
Your rights of access and modification may be exercised by contacting us at
. It is your responsibility to ensure that any information you have provided to us is accurate and up-to-date.