In this privacy statement:
Services refers to any products, services, content, features, technologies or functions and all related websites, applications and services offered by us.
Platform refers to the websites, mobile applications, mobile websites or any other online properties through which we offer you our Services.
- Who are we?
- What data do we collect about you?
2.1.1 Data provided by direct interaction
Registration and other account information
When you register to use our Services, we may collect the following information:
- If you want to register on the Platform, you will only be asked for your email address;
- If you register using a Google account: name, surname and email address;
- If you register using a Facebook account: we collect the name and surname as it appears on your Facebook account and on your Facebook profile. If you have given Facebook permission through the privacy option in the application (an option that will appear immediately before registering on the Platform), we may collect your gender, age or email address, depending on the permissions you have given; and
- If you register using your mobile phone number, we collect your mobile phone number.
Depending on the choices you make when logging into our Services or during the process of using our Services, you may choose to provide, in addition, the following personal data:
- your name;
- residence address;
- Tax Identification Number;
- mobile number;
Communication through the chat functionality on our Platform
When you use our chat feature to communicate with other users, we collect information that you choose to provide to other users through this feature.
Telephone conversations with our Customer Support team
When you contact us by phone or choose to be contacted by phone by one of our Customer Support representatives, we occasionally record the conversation, subject to your express consent, in order to improve our practice of interacting with the customer.
Recordings in video or audio format for specific customer interaction studies
When you expressly agree to participate in interaction studies organized by Classiboats with customers, we will record your interaction with our team. For each customer survey organized by Classiboats, we will provide you with the necessary information on how we process your personal data and why we are doing it.
Participation in our user surveys
In order to improve the quality of its services, Classiboats may occasionally send out surveys to assess users’ general satisfaction with the quality of Classiboats services. In that sense, we will only process the information regarding your “session long” (this is a random identifier assigned when our mobile application is downloaded).
We can also process your email or phone number to contact you and invite you to participate in one of our user experience tests (UX) or an interview with our team.
2.1.2 Data that we collect automatically when you use our Services
When you interact with our Platform or use our Services, we automatically collect the following information about you:
- We collect specific information about the device, such as the operating system version or unique identifiers. For example, the name of the mobile network you are using. We associate that device with the device identifiers in your Classiboats account.
- Depending on the permissions on your device, if you post an article on our Platform, we will automatically collect and process information about your current location. We use a variety of technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile data towers. Your location data allows you to view articles from users near you and helps you post articles in the area you are in. If we need to have access to your location data, a pop-up window will first appear asking you for authorization to access your location data. If you do not allow us to access your location data, you can still use our Services, but with limited functionality. If you allow us to access your location data, such authorization can always be changed in the future, by accessing the Platform settings and disabling permissions related to location sharing. To learn more about the purposes for using your location data and how that data is processed, please refer to Section 4.2 (ii) of this Privacy Statement.
Customer and Registration Data
- Technical details, including your device’s Internet Protocol (IP), time zone and operating system. We will also store your login information (registration date, date of the last password change, date of the last successful login), the type and version of your browser.
- We collect information about your activity on our Platform, including the websites you used to access our Platform, timestamp for each visit, searches performed, advertising listings or banners you have accessed, your interaction with these ads of advertising or listings, duration of your visit and the order in which you accessed the content on our Platform.
Cookies and Similar Technologies
2.1.3 Data from third parties or publicly available sources.
We receive personal data about you from various third parties [and publicly available sources] as described below:
- Certain technical and usage information from analytics data providers, such as Google;
- Contact details for business operations in advertising networks, such as data providers related to operations and service partners (Example: business activity data); and
- Usage data for the Services on the Platform related to the Services or transactions. (Example: data directly related to the ads published on the Platform to prevent fraud and report such cases to the respective entities).
- Do we collect data from minors?
Our Services are not intended for children under 16 and we do not knowingly collect data from anyone under the age of 16. If we realize that a child under 16 has given us your data, we will immediately delete that data.
- Why do we process your personal information?
We only use your personal data when permitted by law. Most of the time, we will use your personal data in the following circumstances:
- When we need to fulfill the contract that we are about to enter into or that we have entered into with you.
- Whenever it is necessary for our legitimate interests to improve our Services and provide you with a secure Platform.
- Whenever we have to comply with legal or regulatory obligations.
- When you give us your express consent (for example, for recordings in audio or video format).
In certain circumstances, we may also process your personal data based on your consent. If we do, we will inform you of the reason and category of personal data to be processed at the time we ask for your consent.
We have set out below a description of how we use your personal data and on what legal bases we are based to do so. We also identify what our legitimate interests are, whenever necessary.
4.1. For the purpose of providing access and providing the Services through our Platform
- If you log in to the Platform using your phone number or email ID, we will use your first and last name, phone number and / or email address to identify you as a user and allow you to access our Platform.
- If you log in using your Facebook account, we will use the name and nickname of your Facebook profile and Facebook email address to identify you as a user on our Platform and allow you to access our Platform.
- We use your email address and mobile phone number to make suggestions and recommendations about our Services that may be of interest to you.
We process the information described above for the proper performance of the contract entered into with you and on the basis of our legitimate interest in performing marketing activities to offer you Services that may be of interest to you.
4.2. To improve your experience on the Platform
- We use clickstream data to
- providing targeted content, for example, providing you with more relevant search results whenever you use our Services.
- to determine how much time you spend on our Platform and how you navigate through our Platform, so that we can understand your interests and improve our Services based on this data. For example, we can provide you with suggestions on content that you can visit based on the content you have accessed.
- to monitor and communicate the effectiveness of advertising campaigns targeted at our business partners and for internal business reviews.
- We use your location data for the following purposes:
- to compile anonymous and aggregated information about the characteristics and behavior of Classiboats users, including for the purposes of business analysis, segmentation and the development of anonymous profiles.
- to measure and monitor your interaction with third party advertising banners that we place on our Platform.
iii. With the help of your login information, which includes your email ID and phone number, we map the different devices (such as computers, mobile phones, tablets) used by you to access our Platform. This allows us to associate your activity on our Platform in a transversal way through devices and helps us to give you a perfectly integrated experience regardless of the device you are using.
- When logging in with your user ID and session long, we may occasionally send you surveys to assess your overall satisfaction with the quality of Classiboats services. Following the sending of the survey, we may also ask you for your email or phone number to contact you and invite you to participate in one of our user experience tests (UX) or in an interview with our team.
- We access and analyze your communications made through our chat functionality with other users, through our Platform, to improve the product and to improve your experience as a user on our Platform (for example, to identify items sold and provide only active ads ). In this sense, we develop and train machine learning models and algorithms to automatically analyze the content of your chat. In order to create and train our machine learning models, our machine learning specialists can manually review exemplary chat content. In these situations, selected machine learning specialists have the right of access, highly restricted, to the chat content. During this analysis process, we identify the content of the chat as much as possible, applying a verification filter to detect and hide personal data, such as names, phone numbers and email addresses. However, there may still be situations beyond our control where the chat content may reveal certain personal data that the user has provided.
We process the information described above based on our legitimate interest in improving your experience on our Platform and in order to guarantee an adequate performance of the contract we have signed with you.
4.3 To provide you with a secure Platform
- We use your phone number, access data and your device’s unique identifiers to manage and protect our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, assistance, communication and storage of Dice).
- We access and analyze your communications made through our chat functionality with other users, through our Platform, for customer satisfaction, security and fraud prevention purposes (for example, to block spam or abusive messages that may have you) sent by other users). In this sense, we develop and train models and algorithms for machine learning, to help Classiboats automatically detect and prevent inappropriate, abusive and fraudulent user behavior. Only in certain situations and circumstances, our security and customer protection specialists will analyze the chat content manually. In these circumstances, access rights are highly restricted to specialists selected for customer protection and safety, who analyze the chat content. During the analysis process, we depersonalize the chat content as much as possible, anonymizing the unique identification values assigned to users. However, there may still be situations beyond our control where the chat content may reveal certain personal data that the user has provided.
We process the information described above to properly comply with our contract with you, to improve our services and on the basis of our legitimate fraud prevention interests.
4.4 To provide you with top of the line customer support
- We record your conversations with the members of our Customer Support Team, subject only to your express agreement;
- If you agree to participate in the occasional interaction studies of Classiboats, we will record your interaction with our team, with a view to better the services we provide you, as our customer.
We process the personal data identified above for further analysis of your interaction with members of our Customer Support Team and sales team (as appropriate) and to improve the way our team members provide services to Classiboats customers.
You can withdraw your consent at any time free of charge through a request to be sent to Classiboats for the contact details identified in Section 14. All processing activities carried out until withdrawal of consent will be valid.
- Processing of Personal Data as part of the Classiboats Developer Portal
The Classiboats Developer Portal is a tool for individuals or companies that want to place their ads on the Classiboats platform.
In order to promote and facilitate access to the services we provide through the Classiboats API as part of the Classiboats Developer Portal, we process the personal data of our users, who are the software developers or individual contractors / collaborators of these programmers (collectively referred to as “Developer” or “Developers”). For the service in question we process: the name of the application, the name and surname of the contact person of the Programmer, as well as the corresponding telephone number.
The use of the Classiboats API services requires the activation of the Classiboats account data. Each time a new application is added by the developer (the “Application”), it is necessary to complete a form for that purpose and send additional information related to the Application and the contact person, in accordance with the provisions of the Terms and Conditions of the Classiboats. The provision of the data required in the form is purely voluntary, however, it is necessary to use the services of the API Classiboats. As part of using the Classiboats API services, we also process data about programmers’ activity in the Terms and Conditions.
We process the information described above in order to properly comply with our contract with you, to improve our services and on the basis of our legitimate interests in terms of preventing fraud or conduct abuse, as well as to ensure that the Application complies with the provisions provided for in our Classiboats Developer Portal Terms and Conditions.
Classiboats is not responsible for the lawfulness of the processing of personal data of users related to the Application added by the Developer (s). The obligation to provide reliable information on the rules for using the Application, security policy and other information required by applicable law, in particular the provisions on the protection of personal data, is the sole responsibility of each Developer. Classiboats considers it mandatory to update and support the Application Developers, namely to guarantee the security and privacy of the users’ data processed by them, in accordance with the Terms and Conditions applicable to the Classiboats Developer Portal.
In order to exercise their rights under the provisions relating to the protection of personal data, any user using the Application must directly contact the Developer or the entity indicated in their legal document / code of conduct for this purpose. That document will determine and describe the rules for using the Application in question.
- How will we inform you about changes to our privacy statement?
We may change this privacy statement from time to time. We will publish the changes on this page and we will inform you of such changes by email or through our Platform. If you do not agree with these changes, you can close your account by accessing your account settings and accessing the delete account option.
- Your rights
In certain circumstances, and under data protection laws, you have rights regarding your personal data.
If you wish to use any of the rights described below, please contact us at email@example.com:
- Right to request access to your personal data (known as the “data subject’s access request”). This allows you to receive a copy of the personal data we have about you and to verify that we are processing it in accordance with the law.
- Right to request corrections to any data we have about you. This allows you to correct any incomplete or incorrect data we have about you, although we are obliged to verify the accuracy of the new data you provide us.
- Right to request a limitation on the processing of your personal data. This allows you to request the suspension of the processing of your personal data in the following circumstances: (a) if you want us to determine the accuracy of the data; (b) whenever our use of the data does not comply with the law; (c) whenever you need us to keep your data, even if you do not need it, in case you need to establish, exercise or defend yourself against lawsuits; or (d) if you have disagreed with our use of your personal data, although we are required to check whether there are any legitimate superior interests in order to continue using it.
- Right to request the deletion of your personal data. This allows you to request that we delete or remove your personal data whenever there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data whenever you have successfully exercised your right to refuse processing (see below), whenever we have processed your information unlawfully or whenever we are required to delete it your personal data for the purpose of complying with local law. Please note that, for certain purposes, we may be legally required to retain your data. Please also refer to section 11.
- Right to object to the processing of your personal data whenever we resort to a legitimate interest (or the legitimate interest of a third party) and whenever there is something related to your personal situation that leads you to contest its processing in these terms, for consider that this could have a fundamental impact on their fundamental rights and guarantees. You also have the right to object whenever we process your personal data for the purposes of direct marketing. In some cases, we may be able to demonstrate that we have legitimate and compelling reasons that override your rights and guarantees to process your information.
- Right to request the portability of your personal data for you or a third party. We will provide you, or provide a third party of your choice, with your personal data in a structured, commonly used, and electronically readable format. Note that this right only applies to automated information for which you initially gave us your consent to use or in situations where we have used the information for the purpose of fulfilling the contract we have entered into with you.
- Right to withdraw consent, at any time, for the processing of your personal data. This does not affect the legality of any processing that we have already carried out on the basis of the consent previously given.
Normally no fees apply: You do not have to pay any fees to access your personal data (or exercise any of the other rights). However, we may charge a reasonable fee if your order is manifestly unfounded, repetitive or excessive. On the other hand, we may refuse to comply with your request in these circumstances.
Response time: We try to respond to all legitimate requests within one month. Occasionally, it may take more than a month if your order is particularly complex or if you have placed multiple orders. In that case, we will notify you and keep you informed.
In addition, you have the right to make a complaint, at any time, to the responsible data protection authority, pursuant to section 15.
However, before submitting a complaint to the data protection authority, we would like to have the opportunity to address your concerns in the first instance, so please contact us at firstname.lastname@example.org
- Communication and marketing
We will communicate with you by email, SMS or notification through the application associated with our Services / Platform to confirm your registration, inform you in case your listing of ads has started / expired and for other transactional messages related to our Services. Since such transactional messages are mandatory for us, you cannot refuse them.
You can, however, ask us, at any time, to stop sending you marketing communications by simply accessing the opt-out link in the email or SMS message sent to you or by changing your communication settings in your account. If you have trouble changing your settings, please contact us at email@example.com
You may receive marketing communications from us if:
- requested such information;
- use our Platform or Services;
- provided us with your details when participating in a contest; or
- if you have registered for a promotion.
- With whom do we share your data?
We may have to share your personal data with the parties listed below, for the purposes of Section 4 above.
Affiliated companies: Classiboats does not own affiliated companies, so you will not be able to share your personal data.
Third Party Service Providers: We use third party service providers to help us with some aspects of our Services, such as cloud storage services, such as Amazon Web Services and Microsoft Azure. Service providers can be located within or outside the “EEA”.
We carry out checks on third party service providers and demand that they respect the security of your personal data and that they treat them in accordance with the law. We do not allow them to use your personal data for their own benefit and only allow them to process your personal data for the specified purposes and in accordance with our instructions.
Law enforcement authorities, regulators and others: We may disclose your personal data to law enforcement authorities, regulators, government or public entities and other third parties to comply with any legal or regulatory requirements.
We may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If there are any changes to our business, new owners may use your personal data as described in this privacy statement.
Publicly available information: Whenever you post an article for sale using our Services, you can choose to make some of your personal information visible to other Classiboats users. This information can include your name, surname, your email address, your location and your contact number. Please note that any information you provide to other users may be shared by them with third parties, so you must demonstrate discretion in this regard.
- International transfers
Whenever we transfer your personal data outside the EEA, we guarantee a similar degree of protection, ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that the European Commission considers to provide an adequate level of data protection. For more information, see European Commission: Adequacy of personal data protection in countries outside the European Union (EU) I.
- Whenever we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection as they have in Europe. For more information, see European Commission: Model contracts for the transfer of personal data to third countries.
- Whenever we use service providers in the United States of America (USA), we will be able to transfer data to them if they are part of the Privacy Shield, which requires similar protection for personal data shared between Europe and the USA. For more information, see European Commission: EU-US Privacy Protection Shield.
- Where do we store your data and for how long?
The data we collect about you will be stored and processed both inside and outside the EEA on secure servers in order to provide the best possible experience for the user. For example: for quick links to the website or mobile application.
We will only retain your personal data for as long as necessary to serve the purposes for which we collect it, including for the purpose of complying with any type of legal, accounting or communication requirements.
To determine the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of personal data, the potential risk of damage from the unauthorized disclosure or use of your personal data, the reasons why we process your data personal data and whether we are able to comply with these reasons by other means, and the applicable legal requirements.
If there is no activity on your account for more than 24 months, we reserve the right to delete your account, which means that you will not be able to use it again. However, we will not delete your account when you have open transactions or are entitled to a refund or credit refund from us. Before your account is deleted, we will contact you to see if you want to continue using your account.
If you have questions regarding the retention period of your personal data, please contact us via email firstname.lastname@example.org
- Technical and organizational measures and security processing
All the information we receive about you is stored on secure servers, and we have implemented technical and organizational measures that are adequate and necessary to protect your personal data. Classiboats continually assesses the security of its network and the suitability of its internal security information program that is designed to (a) help protect your data from accidental or unlawful loss, access or disclosure, (b) identify reasonable foreseeable risks for the security of the Classiboats network, and (c) minimize security risks, including through regular risk assessments and tests. In addition, we ensure that all payment data is encrypted using SSL technology.
Please note that, despite the measures we have implemented to protect your data, the transfer of data via the Internet or other open networks is never completely secure, with the risk that your personal data may be accessed by unauthorized third parties.
- Links to third party websites
For any additional information, or to exercise your rights, please check your account / privacy settings or send an email to email@example.com
- Control entities
For data protection complaints and complaints, contact the data protection authority.
For local data protection matters your local authority can be contacted in your language. In Portugal, you should contact:
CNPD – National Data Protection Commission, headquartered at Rua de São Bento, no. 148 – 3rd
Phone +351 213928400; Fax: +351 213976832