Entale Privacy Policy

Introduction

This privacy policy tells you what to expect when Entale collects and processes your personal data. It applies to information we collect and process about:

  • People who access our content through an embedded player on a web browser

  • People who access our content through our app

Entale Media Ltd is the controller responsible for the processing of your personal data according to this privacy policy.

The personal data we process and why

In this section, you can read about when and why we process your personal data, the categories of personal data concerned, our legal basis for processing and the time period during which the data is stored. As outlined below, what personal data we process about you depends on how you access our content and for what purpose we need to process your data. Our legal basis for the processing also varies depending on why we need to process your data.

1. To give you access to, and to content within, the Entale app

Applicability

We process your data for this purpose when you access our content through:

  • An embedded player in a web browser

  • Our app

 

Categories of personal data processed

We process the following categories of personal data in order to give you access to the app and our content:

  • IP address

  • User Agent

 

Purpose of processing
Your personal data is processed once the app is opened in order to:

  • Identify the receiving device of the content 

  • Be able to deliver content to your player

 

Legal basis

The processing is necessary for our legitimate interest of marketing the app to you and providing requested content within the app. We have performed a balancing test and have concluded that we have a legitimate interest of marketing the app and providing requested content, which is not overridden by your interests of protecting your data being processed for the purposes of providing such marketing information

 

Retention period

Your IP address and User Agent will be retained for 30 days following your latest access to content and thereafter deleted.

2. For direct marketing to our newsletter subscribers
 
Applicability

We process your data for this purpose when you sign up for newsletters at Entale.com

 

Categories of personal data processed

We process the following categories of personal data in order to send you information through our newsletters:

  • Email address

 

Purpose of processing
Your personal data is processed in order to send news and updates about Entale.

 

Legal basis

The processing is based on your consent.

 

Retention period

Your personal data is retained until you choose to unsubscribe from our newsletter by using the opportunity to opt-out.

3. For user support
 

Applicability

We process your data for this purpose when you access our content through all distribution channels.
 

Categories of personal data processed

We process the following categories of personal data in order to provide you with support:

  • Name

  • Email address

  • IP address

  • Your communication with us, including necessary information regarding the matter at hand

 

Purpose of processing

Your personal data is processed in order to:

  • Confirm your identity as an Entale user

  • Communicate with you

  • Answer your questions and solve any problems the matter concerns

 

Legal basis

The processing is necessary for our legitimate interest of providing customer support to you. We have performed a balancing test and have concluded that we have a legitimate interest of providing customer support to you, at your request, which is not overridden by your interests of protecting your data being processed for the purposes of providing such customer support.

 

Retention period

Your personal data is retained for 1 month following the submission of the user support matter or earlier if requested by you.

4. To develop our services
 

Applicability

We may process your data for this purpose when you access our content through all distribution channels.

 

Categories of personal data processed

We may process all collected categories of personal data in order to develop new services. For this purpose we may also compile statistics for analytical purposes.

 

Purpose of processing

Your personal data is processed in order to:

  • Develop and improve Entale’s services

  • Perform statistical analysis based on e.g. geography and demography to understand the users and the target market better

 

Legal basis

The processing is necessary for our legitimate interest of providing improved and more relevant services to you. We have performed a balancing test and have concluded that we have a legitimate interest of developing our services which is not overridden by your interests of protecting your data that is processed

 

Retention period

Your personal data is not stored specifically for the purpose of developing our services and will therefore be deleted when it is not necessary for other purposes.

5. For information security purposes
 

Applicability

We may process your data for this purpose when you access our content through all distribution channels.

 

Categories of personal data processed

We may process all collected categories of personal data in order to protect the security of our services, to prevent or to discover use of our services that is unlawful.

 

Purpose of processing

Your personal data is processed in order to prevent, discover or block misuse or fraudulent behavior.

 

Legal basis

The processing is necessary for our legitimate interest of providing secure services to you based on lawful and fair conduct between the parties. We have performed a balancing test and have concluded that we have a legitimate interest of providing secure services to you which is not overridden by your interests of protecting your data that is processed.

 

Retention period

Your personal data is not stored specifically for information security purposes and will therefore be deleted when it is not necessary for other purposes unless there is a legal obligation to retain your personal data.

6. To comply with our legal obligations
 
Applicability

We may process your data for this purpose when you access our content through all distribution channels.

 

Categories of personal data processed

We may process all relevant collected categories of personal data that is necessary in order to comply with our legal obligations.

 

Purpose of processing

Your personal data is processed in order for us to comply with our legal obligations, e.g. in relation to bookkeeping.

 

Legal basis

The processing is necessary for compliance with a legal obligation to which the Entale is subject.

 

Retention period

Your personal data is retained for a period stipulated in the legislation or decision from the competent authority in question or as long as necessary in order to comply with our legal obligations.

How we collect your personal data

We collect the personal data that you provide to us, e.g. through using the Entale app or if you contact us.
Through our website you can choose to register for Entale’s newsletter. If you choose to do so we will collect your email address.
Regardless of the way you use our services, Entale will collect certain information from your technical equipment such as your IP address, User Agent, language and country settings.

Who we share your data with

 

To fulfil the purposes for our processing of your personal data we share your personal data with companies that provide services to Entale. These companies are only allowed to use your personal information in line with our instructions and may not use your personal data for their own purposes. They are also obliged to protect your personal data. We share your personal data with the following companies:

  • Instabug who provides us with a support tool

  • Google who provides us with a mail server for support

  • Mailchimp who provides us a service for sending newsletters

We may also share your personal data with other partners within the marketing analysis field. The personal data will in such cases not be used for purposes that are incompatible with the purposes for which it was originally collected.

We may be obliged to share your data with public authorities at their request in accordance with applicable legislation or a decision by a competent authority.

Where we process your personal data

 

Some of our suppliers may be located in a country outside the European Union or European Economic Area. When we share your data with such suppliers in order to provide our services to you we will always perform necessary security measures in order to make certain that the data we share is handled in accordance with applicable legislation.


Some of our suppliers are located in the USA and in order to protect your personal data we ensure that our suppliers in the USA are certified under the Privacy Shield. Consequently, transfers of personal data to such suppliers are based on a decision by the European Commission that an adequate level of protection of the personal data is ensured in accordance with GDPR article 45.1

 
Your rights
 
Right to be informed

You have the right to be informed about the collection and use of your personal data including, in essence, our purposes for processing your personal data, our lawful basis for the processing, our retention periods for that personal data, who it will be shared with and your rights. We aim to provide you with such information through this Privacy Policy.
 

Right of access

You have the right to obtain confirmation that your data is being processed, access to your personal data and other supplementary information (this information largely corresponds to the information in this Privacy Policy). A copy of your personal data will be provided free of charge. However, we may charge a ‘reasonable fee’ to comply with requests for further copies of the same information or when a request is manifestly unfounded or excessive, particularly if it is repetitive. 

 

You can submit an access request regarding your personal data in our mobile app, using the feedback button. If we receive an access request we may contact you for further information regarding your request and to establish your identity. We will answer your access requests without delay within one month.

 

Right to rectification

We have a responsibility to ensure that your personal data is accurate. However, you may provide us with additional data if our data is incomplete or require rectification if you have identified that your personal data is incorrect. When your data is being corrected we will inform any recipients we have disclosed the data to, about the rectification, unless this proves impossible or involves disproportionate effort. We will also, at your request, inform you about which recipients have been informed of the rectification.

 

Right to erasure

You have the right to have your personal data erased if:

  • the personal data is no longer is necessary for the purpose which we originally collected or processed it for

  • we are relying on consent as our lawful basis for processing the data, and you withdraw your consent

  • we are relying on legitimate interests as our basis for processing, you object to the processing of your data, and there is no overriding legitimate interest to continue the processing

  • we are processing the personal data for direct marketing purposes and you object to that processing

  • we have processed the personal data unlawfully

  • we have to do it to comply with a legal obligation

  • If your data is erased, we will inform any recipients of your data that this erasure has been undertaken unless this proves impossible or involves disproportionate effort.

 

Right to restrict processing

You have the right to request that we restrict the processing of your personal data in the following circumstances:

  • you contest the accuracy of your personal data during a period when we are verifying the accuracy of the data;

  • the data has been unlawfully processed and you oppose erasure and request restriction instead;

  • we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim; or

  • you have objected to us processing your data, and we are considering whether our legitimate grounds override your grounds.

  • If we have restricted the processing of your personal data temporarily, we will inform any recipients of your personal data of such restriction unless this proves impossible or involves disproportionate effort.


Right to data portability

You may under certain circumstances have a right to data portability. This means the right to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer your personal data easily from one IT environment to another. The right to data portability only applies:

  • to personal data you have provided to us as controller;

  • where the processing is based on your consent or for the performance of a contract; and

  • when the processing is carried out by automated means.


Right to object to processing based on legitimate interests

You have a right to object to the processing of your personal data based on our legitimate interests. If you choose to object, please specify which processing the objection refers to. We are obliged to stop processing your personal data based on our legitimate interests unless:

  • we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms, or

  • the processing is for the establishment, exercise or defence of legal claims.

 

Right to object to processing for direct marketing purposes

You have a right to object to our processing of your personal data for direct marketing purposes at any time by unsubscribing from future messages. This is done by clicking on a link named “unsubscribe” in the email you have received from us. Your personal data will thereafter no longer be processed for direct marketing purposes.

Right to withdraw consent

When we process your personal data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall however not affect the lawfulness of processing based on your consent before its withdrawal. You can withdraw your consent by contacting us, see contact information below.​

 

Changes to this Privacy Policy

We keep our privacy policy under regular review and we may sometimes need to make updates or changes to it. This privacy policy was last updated on 2018-05-22.​

How to contact us

If you want to request information about our privacy policy or use your rights as expressed above, you can contact us at:

Entale ℅ Founders Factory

Northclifffe House

Young Street

London

W8 5EH

United Kingdom


Email: privacy@entale.com

Entale is a Founders Factory company