If you are not resident in the EU, EEA and Switzerland please click here
Effective date: 14 Mar 2019
1.1.1 INTRODUCTION
MARPLE is firmly committed to the security and protection of personal information of our Users. This Privacy Policy describes how MARPLE will collect, use, share and process personal information. Capitalized terms not defined in this Privacy Policy are defined in the MARPLE Terms of Service.
1.1.2 DATA CONTROLLER AND CONTRACTING PARTY
If you reside in the European Union (EU), European Economic Area and Switzerland (“Europe”), You are entering into the Terms of Service with Cuutio Software Oy and Cuutio Software Oy will be the controller of Your personal information. If you do not reside in Europe the applicable terms are available here.
1.1.3 BRIEF SUMMARY:
In simple terms:
We process Your profile data (name, email etc.) and information about Your activity on the MARPLE application including device information, IP address and location to provide, improve, analyze and personalize the Services for You.
Subject always to obtaining your prior consent, we may:
- provide your information to third parties (such as Google and advertising networks) to serve more relevant advertisements or special offers and promotions to You
1.1.4 1. WHAT PERSONAL INFORMATION WE COLLECT
1.1.4.1 1.1 USER PROFILE
When You create a user profile in the Services, MARPLE will collect the information provided by You. In order to create a user profile, You must register Your first name, last name, email address and country of residence. Additional information that may be provided at Your option include, but is not limited to, phone number, Facebook page, Twitter address, LinkedIn profile and Google profile. MARPLE may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available. If You register for a Paid Service, MARPLE will collect Your payment and billing information.
1.1.4.2 1.2 INSTALLATION AND USE
When You install and use the Services, MARPLE will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; connection information; screen resolution; usage statistics; default communication applications; device log and event information; logs, version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have selected and indicated as positive or negative or sent to us and information about the ads You see and/or engage with; the search phrases You use; order information and other usage activity and data logged by MARPLE’s servers from time to time. MARPLE may collect some of this information automatically through the use of cookies and You can learn more about our use of cookies in our Cookie Policy.
Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.
1.1.4.3 1.3 THIRD-PARTY SERVICES
You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third-party services e.g. social networking services and payment services, in order for the Services to interoperate with such third-party services. You may use such third-party services to create Your user profile or log in to our Services, share information with such third-party services, or connect Your user profile with the respective third-party services. Such third-party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information and information about the advertisements You have been shown or may have clicked on). You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third-party service. We will never store any passwords created for any third-party services.
1.1.4.4 1.4 OTHER INFORMATION YOU MAY PROVIDE
You may provide us with various information in connection with Your interaction with our Services. For example, You may through tagging functionality associate an email address, that is not registered in the MARPLE database or belongs to a User, with a business or name. MARPLE may also from time to time offer You the opportunity to provide information on Your experience from using the Services or to participate in contests, surveys or other promotions. MARPLE will collect the information You provide in connection therewith, as well as any other information You provide through the Services or when You communicate or interact with us.
1.1.5 2. HOW WE USE YOUR PERSONAL INFORMATION
1.1.5.1 2.1 PROVIDE, IMPROVE AND PERSONALIZE OUR SERVICES
MARPLE may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third-party providers. More specifically, MARPLE may use such information to:
- send in application push notifications and reminders and deliver messages via the Services
- maintain a database of selected search results, positive and negative indicators and public website content
- enable You to use and share Your information in connection with Your registration, login or other use of third-party services e.g. payment service providers, online services, social networking sites and other third-party APIs;
- collect public website content and connect it to other collected information
- provide customer support, respond to Your queries, investigate and resolve issues related to the Services;
- otherwise improve our Services, business and operations.
1.1.5.2 2.2 STATISTICAL DATA FROM THE SERVICES
We use aggregated or anonymized personal information for statistical and analytical purposes. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise. We may collect, use, transfer, and disclose non-personal information for any purpose.
1.1.5.3 2.3 PERSONALIZE OUR ADVERTISING AND COMMUNICATIONS
Subject to the choices You make upon registration and in Your settings at any time, we may use the information collected, as set out above, to provide You with location and interest-based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services. Furthermore, we may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, push notices and similar notifications about MARPLE’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.
1.1.5.4 2.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of MARPLE, its Users or any other person and verify provided User profile information with third-party providers and ensure technical service functionality and data accuracy, perform troubleshooting and prevent or detect fraud, security breaches or illegal activities.
1.1.6 3. DISCLOSURE OF PERSONAL INFORMATION
In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2, MARPLE may disclose personal information if we believe such action is necessary to:
- comply with the law, or legal process served on us;
- protect and defend our rights and the enforcement of our agreements; or
- protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.
We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, measuring the effectiveness of ads and services and facilitating payments as well as potential partners who may wish to work with us to provide other services that interact or are integrated with our Services. MARPLE will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. Subject to the choices You make upon registration and in Your settings, MARPLE may share personal information with third-party advertisers, agencies and networks (such as Google). Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services. The information may be collected by such third parties by use of cookies, or similar technologies, and You can learn more about the use of cookies in our Cookie Policy.
We may disclose and transfer Your Information to our associated or affiliated organizations or related entities and to any third-party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
1.1.7 4. LEGAL BASES AND DATA RETENTION
MARPLE will collect and process Your personal information in order to perform the contract with You (e.g. to deliver the Services), based on Your consent (i.e. the choices You make upon registration and in Your settings) or based on a legitimate interest of MARPLE (which is not overridden by your interests or fundamental rights and freedoms). Such legitimate interests of MARPLE include to protect and maintain the security of the Services, to create and maintain search result and content databases, to understand and improve our Services and user relationships and to administer our business and customer support. Where we process data based on Your consent, You may withdraw your consent at any time by contacting us.
MARPLE will retain Your personal information while You maintain a user profile in the Services. You may at any time choose to delete Your user profile and Your personal information via Your settings. If You make such choices, Your personal information will no longer be available in the Services. We will retain Your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We may also retain Your personal information in order to accommodate Your choices regarding marketing.
1.1.8 5. INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES
The MARPLE Services may use cloud-based services and subcontract storage or processing of Your information to third parties located in countries other than Your home country in order to provide the Services, including e.g. the USA. Information collected within Europe may, for example, be transferred to and processed in a country outside of Europe, which may not provide the same level of protection for personal data as within Europe. We use Model Contractual Clauses adopted by the EU Commission as a legal mechanism for the international transfer of data to a third party located in a country outside Europe. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. MARPLE has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.
1.1.9 6. ACCESSING AND CONTROLLING YOUR PERSONAL INFORMATION
MARPLE provides many choices for You to control and manage Your personal information via the settings in the MARPLE Services. Subject to applicable law, you may also have the following rights in relation to Your personal information:
Right of access: You may request confirmation as to whether or not personal information is being processed by MARPLE and to obtain a copy of that information. We may decline to process requests that are vexatious or frivolous or extremely impractical, jeopardize the privacy of others, or for which access is not otherwise required by applicable law.
Right to rectification: You may request rectification if Your personal information is inaccurate.
Right to erasure: You may request that your personal information is erased in certain situations e.g. if it is no longer necessary to provide the Services to You.
Right to object: You may object to the processing of Your personal information in certain situations e.g. for use of Your data for ad targeting.
Right to restriction: You may request restrictions of the processing of Your personal information in certain situations e.g. if Your personal information is inaccurate or unlawfully processed.
Right to data portability: You may request to receive personal information provided by You in machine-readable format.
You may contact MARPLE for assistance using the contact information below, and we will consider your request in accordance with applicable law.
1.1.10 7. CHILDREN’S PRIVACY
We do not intentionally or knowingly collect or solicit information from children under the relevant age of consent under the laws of their respective jurisdictions or knowingly allow such persons to register for the Services. The Services are not directed at children under the relevant age of consent under the laws of their respective jurisdictions. If you believe that we might have information from or about a child under the relevant age of consent, please contact us at hello@marple.app.
1.1.11 8. CHANGES TO THIS PRIVACY POLICY
MARPLE may at any time change this Privacy Policy. MARPLE will notify the Users of such changes by push notice or via a notice in the Services or by other means. If You object to any changes, You may uninstall the MARPLE applications and cease using the Services. Your continued use of the Services after MARPLE have communicated changes to this Privacy Policy, will mean that the collection, use, sharing and processing of Your personal information is subject to the new Privacy Policy. We may from time to time set out more detailed information on how we process your personal information in relation to particular Services in supplemental Privacy Notices which shall be incorporated into and form part of this Privacy Policy.
1.1.12 9. COOKIES
As described in our Cookie Policy, we use cookies, web beacons, flash cookies, HTML 5 cookies, pixel tags and other web application software methods, including mobile application identifiers, to help us recognize you across the Services, learn about your interests both on and off the Services, improve your experience, increase security, measure use and effectiveness of the Services, and serve advertising. You can control Cookies through your browser settings and other tools. By interacting with the Services, you consent to the use and placement of Cookies on your device in accordance with this Privacy Policy, which by reference incorporates our Cookie Policy.
1.1.13 10. CONTACT US
For questions or complaints related to this Privacy Policy or the processing of Your personal information, we encourage You to contact our Data Protection Officer via hello@marple.app. You can also reach us by physical mail at the following address: Data Protection Officer, Cuutio Software Oy, Reg. No. 2397231-2, Ludviginkatu 6, 00130, Helsinki, Finland. If MARPLE cannot resolve Your concern or if it is inconvenient to contact us, residents in Switzerland may raise the matter with the Swiss Federal Data Protection and Information Commissioner and residents in other countries in Europe with the Finnish Data Protection Authority.
PRIVACY POLICY
If you are resident in the EU, EEA and Switzerland please click here
Effective date: 14 Mar 2019
MARPLE is firmly committed to the security and protection of personal information of our Users and their contacts. This Privacy Policy describes how MARPLE will collect, use, share and process personal information. Capitalized terms not defined in this Privacy Policy are defined in the MARPLE Terms of Service.
If you reside outside the European Union, European Economic Area and Switzerland (“Europe”), You are entering into the Terms of Service with MARPLE International LLP and the terms of this Privacy Policy apply to You. If you reside in Europe the applicable terms are available here.
By accepting the MARPLE Privacy Policy and/or using the Services You consent to the collection, use, sharing and processing of personal information as described herein. If You provide us with personal information about someone else, You confirm that they are aware that You have provided their information and that they consent to our use of their information according to our Privacy Policy. You may opt-out at any time to prevent further use of the information shared via the Services.
1.1.1 1. PERSONAL INFORMATION COLLECTED
1.1.1.1 1.1 USER PROFILE
When You create a user profile in the Services, MARPLE will collect the information provided by You. In order to create a user profile, You must register Your first name, last name, email address and country of residence. Additional information that may be provided at Your option include, but is not limited to, phone number, Facebook page, Twitter address, Linkedin profile and Google profile. MARPLE may supplement the information provided by You with information from third parties and add it to the information provided by You e.g. demographic information and additional contact information that is publicly available.
1.1.1.2 1.2 INSTALLATION AND USE
When You install and use the Services, MARPLE will collect personal information from You and any devices You may use in Your interaction with our Services. This information may include e.g.: geo-location; Your IP address; device ID or unique identifier; device manufacturer and type; device and hardware settings; applications installed on your device; ID for advertising; ad data, operating system; web browser; operator; connection information; screen resolution; usage statistics; default communication applications; device log and event information; logs, version of the Services You use and other information based on Your interaction with our Services such as how the Services are being accessed (via another service, web site or a search engine); the pages You visit and features you use on the Services; the services and websites You engage with from the Services; content viewed by You, content You have selected and indicated as positive or negative or sent to us and information about the ads You see and/or engage with; the search phrases You use; order information and other usage activity and data logged by MARPLE’s servers from time to time. MARPLE may collect some of this information automatically through the use of cookies and You can learn more about our use of cookies in our Cookie Policy.
Some information, including, but not limited to, usage information and other information that may arise from Your interaction with the Services, cannot be used to identify You, whether in combination with other information or otherwise and will not constitute personal information for the purposes of this Policy.
1.1.1.3 1.3 THIRD PARTY SERVICES
You may provide us with Your user identifier information regarding, or to enable Your usage of, certain third party services e.g. social networking services and payment services, in order for the Services to interoperate with such third party services. You may use such third-party services to create Your user profile or log in to our Services, share information with such third party services, or connect Your user profile with the respective third party services. Such third party services may automatically provide us with access to certain personal information retained by them about You (e.g., your payment handle, unique identification information and information about the advertisements You have been shown or may have clicked on). You may be able to control the personal information You allow us to have access to through the privacy settings on the respective third-party service. We will never store any passwords created for any third party services.
1.1.1.4 1.4 OTHER INFORMATION YOU MAY PROVIDE
You may provide us with various
information in connection with Your interaction with our Services. For example,
You may through tagging functionality associate an email address, that is not
registered in the MARPLE database or belongs to a User, with a business or
name. MARPLE may also from time to time offer You the opportunity to provide
information on Your experience from using the Services or to participate in
contests, surveys or other promotions. MARPLE will collect the information You
provide in connection therewith, as well as any other information You provide
through the Services or when You communicate or interact with us.
1.1.2 2. USE OF PERSONAL INFORMATION
1.1.2.1 2.1 PROVIDE, IMPROVE AND PERSONALIZE OUR SERVICES
MARPLE may use the personal information collected to provide, maintain, improve, analyze and personalize the Services to its Users, partners and third-party providers. More specifically, MARPLE may use such information to:
- send in application push notifications and reminders and deliver messages via the Services
- maintain a database of selected search results, positive and negative indicators and public website content
- enable You to use and share Your information in connection with Your registration, login or other use of third-party services e.g. payment service providers, online services, social networking sites and other third party APIs;
- collect public website content and connect it to other collected information
- provide customer support, respond to Your queries, investigate and resolve issues related to the Services;
- otherwise improve our Services, business and operations.
1.1.2.2 2.2 STATISTICAL DATA FROM THE SERVICES
We use aggregated or anonymized personal information for statistical and analytical purposes. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise. We may collect, use, transfer, and disclose non-personal information for any purpose.
1.1.2.3 2.3 PERSONALIZE OUR ADVERTISING AND COMMUNICATIONS
We may use any of the information collected, as set out above, to provide You with location and interest-based advertising, marketing messaging, information and services. We may also use the collected information to measure the performance of our advertising and marketing services.
We may contact You for verification purposes or with information pertaining to the Services or special offers, e.g. newsletter e-mails, push notices and similar notifications about MARPLE’s and our business partners’ products and services. We also use the collected information to respond to you when you contact us.
1.1.2.4 2.4 COMPLIANCE WITH LAWS AND PREVENTION OF FRAUDULENT OR ILLEGAL ACTIVITIES
We may use the collected information to comply with applicable laws and to enforce our agreements and protect and defend the rights or safety of MARPLE, its Users or any other person and verify provided User profile information with third-party providers and ensure technical service functionality and data accuracy, perform troubleshooting and prevent or detect fraud, security breaches or illegal activities.
1.1.3 3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In addition to the sharing and disclosure of personal information that is included as part of the functionality of the Services as described in section 2 above, MARPLE may disclose personal information if we believe such action is necessary to:
- comply with the law, or legal process served on us;
- protect and defend our rights and the enforcement of our agreements; or
- protect the security and safety of Users or members of the public or other aspects of public importance, provided, of course, that such disclosure is lawful.
We transfer information to trusted vendors, service providers, and other partners who support our business and Services, such as providing technical infrastructure services, bug testing, analyzing how our Services are used, measuring the effectiveness of ads and services and facilitating payments as well as potential partners who may wish to work with us to provide other services. MARPLE will always require these third parties to take appropriate organizational and technical measures to protect personal information and to observe applicable legislation. MARPLE may also share personal information with third-party advertisers, agencies and networks. Such third parties may use this information for analytical and marketing purposes e.g. to provide measurement services and targeted ads and for improvement of products and services. The information may be collected by such third parties by use of cookies, or similar technologies, and You can learn more about the use of cookies in our Cookie Policy.
We may disclose and transfer Your Information to our associated or affiliated organizations or related entities and to any third party who acquires, our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets.
1.1.4 4. INFORMATION SECURITY AND TRANSFER OF PERSONAL INFORMATION TO OTHER COUNTRIES
In order to provide the Services, MARPLE will transfer, process and store personal information in a number of countries, including but not limited to India, and may also use cloud-based services for this purpose. MARPLE may also subcontract storage or processing of Your information to third parties located in countries other than Your home country. Information collected within one country may, for example, be transferred to and processed in another country, which may not provide the same level of protection for personal data as the country in which it was collected. You acknowledge and agree that MARPLE may transfer Your personal information as described above for purposes consistent with this Privacy Policy. We take all reasonable precautions to protect personal information from misuse, loss and unauthorized access. MARPLE has implemented physical, electronic, and procedural safeguards in order to protect the information, including that the information will be stored on secured servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet or method of electronic storage is 100% secure.
1.1.5 6. ACCESSING AND UPDATING PERSONAL INFORMATION
MARPLE may on its own initiative, or at Your request, replenish, rectify or erase any incomplete, inaccurate or outdated personal information retained by MARPLE in connection with the operation of the Services. When required by applicable law, You have the right to know what personal information is stored about You and to have any such information corrected or deleted on Your request. See contact details below.
1.1.6 7. MINORS
Services are not intended for or designed to attract anyone under the relevant age of consent to enter into binding legal contracts under the laws of their respective jurisdictions. MARPLE does not intentionally or knowingly collect personal information through the Services from anyone under that age. We encourage parents and guardians to be involved in the online activities of their children to ensure that no personal information is collected from a child without their consent.
1.1.7 8. CHANGES TO THIS PRIVACY POLICY
MARPLE may at any time with or without a separate notice change this Privacy Policy, and You are encouraged to review this Policy from time to time. In case of substantial changes, MARPLE will notify the Users by push notice or via a notice in the Services. Your continued use of the Services after a notice of changes has been communicated to You or published on our Services shall constitute consent to the changed policy.
1.1.8 9. COOKIES
As described in our Cookie Policy, we use cookies, web beacons, flash cookies, HTML 5 cookies, pixel tags and other web application software methods, including mobile application identifiers, to help us recognize you across the Services, learn about your interests both on and off the Services, improve your experience, increase security, measure use and effectiveness of the Services, and serve advertising. You can control Cookies through your browser settings and other tools. By interacting with the Services, you consent to the use and placement of Cookies on your device in accordance with this Privacy Policy, which by reference incorporates our Cookie Policy.
1.1.9 10. CONTACT
If You have any additional questions about MARPLE’s Privacy Policy or want to make a request regarding certain personal information, You are encouraged to contact MARPLE. The contact information is:
Cuutio Software Oy, Reg. No. 2397231-2, Ludviginkatu 6, 00130, Helsinki, Finland.
You can also send Your inquiries (including in relation to any grievances to our Grievances Officer) via email to hello@marple.app.