Organization means Orbu.AI
DPA means the Data Protection Act 2018 which implements the EU’s General Data Protection Regulation.
Responsible Person means Chief Compliance Officer of Orbu.AI.
Register of Systems means a register of all systems or contexts in which personal data is processed by the Organisation.
I. Data protection principles The Organisation is committed to processing data in accordance with its responsibilities under the DPA. DPA requires that personal data shall be: processed lawfully, fairly and in a transparent manner in relation to individuals; collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay; kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the DPA in order to safeguard the rights and freedoms of individuals; and processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
II. General provisions This policy applies to all personal data processed by the Organisation. The Responsible Person shall take responsibility for the Organisation’s ongoing compliance with this policy. This policy shall be reviewed at least annually. The Organisation will register with the Information Commissioner’s Office as an organisation that processes personal data.
III. Lawful, fair and transparent processing To ensure its processing of data is lawful, fair and transparent, the Organisation shall maintain a Register of Systems. The Register of Systems shall be reviewed at least annually. Individuals have the right to access their personal data and any such requests made to the Organisation shall be dealt with in a timely manner.
IV. Lawful purposes
All data processed by the Organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
The Organisation shall note the appropriate lawful basis in the Register of Systems.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Organisation’s systems.
V. Data minimisation The Organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
VI. Accuracy The Organisation shall take reasonable steps to ensure personal data is accurate. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
VII. Archiving / removal
To ensure that personal data is kept for no longer than necessary, the Organisation shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
The archiving policy shall consider what data should/must be retained, for how long, and why.
The Organisation shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information. When personal data is deleted this should be done safely such that the data is irrecoverable. Appropriate back-up and disaster recovery solutions shall be in place. IX. Breach In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website). Orbu Social App Data Policy This policy describes the information we process to support products and features offered by Places App, Inc, dba Honeycommb (Products). I. What kinds of information do we collect? Things you and others do and provide. Information and content you provide. We collect the content, communications, and other information you provide when you sign up for an account, create or share content, message or communicate with others. This can include information in or about the content you provide (like metadata), such as the date a file was created, file dimensions, file types. Our systems automatically process content and communications you and others provide to analyze context and what’s in them for the purposes of improving user experience. Networks and connections. We collect information about the people, accounts, hashtags, and groups you are connected to and how you interact with them across our Products, such as people you communicate with the most or groups you are part of. Things others do and information they provide about you. We receive and analyze content, communications and information that other people provide when they use our Products. This can include information about you, such as when others send a message to you. Device Information. As describe below, we collect information from and about the computers, phones, and other web-connected devices you use that integrate with our Products, and we combine this information across different devices you use. Information we obtain from these devices include: Device attributes: information such as the operating system, hardware and software versions, device carrier, and display sizes. Device operations: information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements. Identifiers: unique identifiers, device IDs, and other identifiers such as associated provider account identifiers. Data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, camera, or photos. Network and connections: information such as the name of your mobile operator or ISP, language, time zone, and IP address. Cookie data: data from cookies stored on your device, including cookie IDs and settings. Information from partners. Advertisers and publishers can send us information through APIs to our platform. These partners provide information about your activities outside of our Products including information about your devices and websites you visit - whether or not you have an account or are logged into the platform. Partners receive your data when you visit or use their services or through third parties they work with. We require each of these partners to have lawful rights to collect, use and share your data before providing any data to us. II. How do we use this information? We use the information we have (subject to choices you make) as described below and to provide and support the Products and related services. Here’s how: Provide, personalize and improve our Products. We use the information we have to deliver our Products, including to personalize features and content and make suggestions for you. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Products, and the people, places, or things you’re connected to and interested in on and off our Products. Location-related information: We use location-related information-such as your current location, where you live, the places you like to go-to provide- to personalize and improve our Products, including ads, for you and others. Location-related information can be based on things like precise device location (if you’ve allowed us to collect it), IP addresses, and information from you and others’ use of our Products. Product research and development: We use information we have to develop, test and improve our Products. Ads and other sponsored content: We use the information we have about you-including information about your interests, actions and connections-to select and personalize ads, offers and other sponsored content that we show you. Provide measurement, analytics, and other business services. We use the information we have to help advertisers and other partners measure effectiveness and distribution of their ads and services. Promote safety, integrity and security. We use the information we have to verify accounts, and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off of our Products. Communicate with you. We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us. III. How is this information shared? Your information is shared with others in the following ways: Sharing on our Products People and accounts you share and communicate with. When you share and communicate using our Products, you are sharing with the audience that you select. For example, when you post generally, you are sharing to all members of the community. Similarly, when you post to a group, the post is shared with the members of the group as well as the community, dependent on the group’s settings. Your network can also see actions you have taken on our Products, including engagement with ads, sponsored posts, other posts, and other users. Public information can be seen by anyone, on or off our Products, including if they don’t have an account. This includes your username, any information you’ve share with a public audience. Public information can also be seen, accessed, reshared, or downloaded through third-party services such as search engines, and APIs. Content others share or reshare about you. You should consider who you choose to share with, because people who can see your activity on our Products can choose to share it with others on and off our Products, including people and businesses outside the audience you shared with. Also, when you comment on someone else’s post, your comment is visible to anyone who can see the other person’s content. New Owner. If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner. Sharing with Third-Party Partners We work with third-party partners who help us provide and improve our Products. We don’t sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Partners who use our analytics services. We provide aggregated statistics and insights that help people and businesses understand how people are engaging with posts, videos, and other content on and off our Products. Advertisers. We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing. We don’t share information that personally identifies you (information such as your name or email address). Measurement Partners. We share information about you with companies that aggregate it to provide analytics and measurement reports to our partners. Vendors and service providers. We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys. Law enforcement or legal requests. We share information with law enforcement or in response to legal requests. IV. How can I manage information about me? We provide you with the ability to access, rectify, port and erase your data. We store data until it is no longer necessary to provide our services or until your account is deleted - whichever comes first. This is a case-by-base determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things you have posted, such as your photos or posts, and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted. V. How do we respond to legal requests or prevent harm? We access, preserve and share your information with regulators, law enforcement or others: In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include to legal requests from jurisdictions outside of the United States when we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. When we have a good faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of our Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property, or Products), you or others, including as part of investigations or regulatory inquiries, or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activities on and off our Products. Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent abuse or other term violations VI. How will we notify you of changes to this policy? We will notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Products.