Collection and Use of PII Our primary goals in collecting information are to provide and improve our services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our services. How we collect and use information:
- When you register for a basic account we collect your email address, and the date of birth. (“Personally Identifiable Information” or “PII”).
- Please note, on Android we require the Get_Accounts permission to associate your email with your ChatGum account. Android SDK combines “GET_ACCOUNTS” into the contacts permission group. However, we do not collect, upload, or store your contacts. For more information regarding this permission please read this page.
- For additional Services beyond the basic account, we may ask you for additional information.
How we use your PII
- We also use PII to help us develop, deliver, and improve our Services.
- Google analytics data is used to improve our app and delivery of our content,
- Compliance with valid legal process
- E-mails will be used for correspondence
- From time to time, we may use your PII to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. We may also use PII for internal purposes such as auditing, data analysis, and research to improve ChatGum’s Services and customer communications.
Collection and Use of Non-PII We also collect non-PII − data in a form that does not permit direct association with any specific individual. We may collect, use, transfer, and disclose non-PII for any purpose. We may collect information such as language, IP address, unique device identifier, location, and the time zone where the Services are used so that we can better understand customer behavior and improve our Services. If we do combine non-PII with PII the combined information will be treated as PII for as long as it remains combined.
Disclosure to Third Parties At times ChatGum may make certain PII available to strategic partners that work with ChatGum to provide products and services, or that help ChatGum market to customers. For example, when you make a purchase through the Apps, you authorize ChatGum and its third party payment processor to exchange the payment information you provide to us to carry out your purchase on the Services. PII will only be shared by ChatGum to provide or improve our Services; it will not be shared with third parties for their marketing purposes.
Service Providers ChatGum shares PII with companies who provide services such as hosting, 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.. Others It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for ChatGum to disclose your PII. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all PII we collect to the relevant third party.
Protection of PII ChatGum takes precautions — including administrative, technical, and physical measures — to safeguard your PII against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. When you use ChatGum Apps or post on a chat room, or social networking service, the PII you share is visible to other users and can be read, collected, or used by them. You are responsible for the PII you choose to submit in these instances. For example, if you list your name and email address in a board posting, that information is public. Please take care when using these features.
Control/Access to PII For other PII, we make good faith efforts to provide you with access to such PII so you can request that we correct or delete the PII we have about you. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. You may delete your account and associated PII within the app. Go to settings -> Delete Account. Access, or correction requests can be made by contacting ChatGum at PII@chatgum.com. Please include your username, approximate date of account creation, last device used, and email connected to the account. If we cannot authenticate your account then requests may be denied or ignored.
Although our website is a general audience site, we restrict the use of our service to individuals age 17 and above. We do not knowingly collect PII from users under 17.
Location-Based Services In some cases we collect and store information about where you are located, such as by converting your IP address into a rough geolocation. We may use location information to improve and personalize our Services for you.
RIGHTS OF THE DATA SUBJECT Right of Confirmation. Each data subject has the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal information concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller. Right of Access. Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal information stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal information concerned;
- the recipients or categories of recipients to whom the personal information have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal information will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal information, or restriction of processing of personal information concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal information are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Moreover, the data subject has the right to obtain information as to whether personal information are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller. Right to Rectify. Each data subject has the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal information concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal information completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they may, at any time, contact our Data Protection Officer or another employee of the controller. Right to Erasure. Each data subject has the right granted by the European legislator to obtain from the controller the erasure of personal information concerning him or her without undue delay, and the controller shall have the obligation to erase personal information without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal information are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal information has been unlawfully processed.
- The personal information must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal information has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
How do I submit a question to ChatGum’s Data Protection Officer (DPO), and what is their role?
ChatGum’s DPO is responsible for guiding our compliance with privacy regulation in the EU. They are the point of contact for European privacy regulators and questions and concerns from our users about data privacy.
For erasure requests please refer to section Control/Access to PII.
If you have other questions pertaining to your personal data you may contact our DPO at DPO@chatgum.com