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Last updated: 12th April, 2023

This version replaces any other Privacy Policy previously applicable from this date.

Barbary Software SL (“we”, “us”, “our”) are committed to protecting and respecting your privacy.

This privacy policy (“Privacy Policy”) and any other documents referred to in it sets out the basis on which we collect and process your personal data as a data controller when you use our website or services.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://featureupvote.com, (“Site”) or using our services or apps, (“Services”) you are accepting and consenting to the practices described in this Privacy Policy.

Please note:
This Privacy Policy does not apply to any data you provide to us when we process personal data on your behalf as your data processor i.e. where we process customer data within the cloud service we provide to you, as a business to business service provider.

DATA CONTROLLER

For the purposes of EU and UK data protection laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the data controller is Barbary Software SL of Carrer Doctor Trueta 65, 08005 Barcelona, Spain.

We collect and use the personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

To the extent we process your personal data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.

PERSONAL DATA WE MAY COLLECT FROM YOU

We may collect and process personal data about you. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data: includes first name, last name, and username or similar identifier.

Contact Data: includes billing address, email address, company name and registration number

Financial Data: includes bank account and payment card details.

Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data: includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or the Services.

Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data: includes information about how you use our Site and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site and Services (including date and time).

Marketing and Communication Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Aggregated Data: We also collect, use and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Special Category Data: We do not collect, store and/or use special category data about you.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including via:

PERSONAL DATA WE RECEIVE FROM OTHER SOURCES

We may receive personal data about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site or via the Services.

We work closely with third parties. Details about these third parties and the information they provide to us is set out in our GDPR Policy, which includes, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and may receive the following personal data about you from them:

COOKIES

We use cookies on our Site and in the Services to distinguish you from other users of our Service. This allows us to provide core functionality when you use the Service.

What are cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the Site. Cookies can be “persistent” or “session” cookies.

We use persistent cookies and session cookies.

Persistent Cookies

A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across the Site (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future logins to the Site or Services.

Session Cookies

A session cookie allows the Site or Services to link your actions during a browser session. We use session cookies to enable certain features of the Site or Services, to better understand how you interact with the Site or Services and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site or Services and then close your browser.

Which cookies we use and why

The table below explains the cookies we use and why we use each of them.

CookieTypePurposeDuration
Google Analytics:
_gid
_ga
Tracking cookiesThese third party cookies are used to collect information about how visitors use our Site and Services. We use the information to compile reports and to help us improve the Site and Services. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited. If you do not allow these cookies we will not be able to include your visit in our statistics.You can read the full Google Analytics privacy policy at: https://policies.google.com/privacy.Two years
fuv_session_id
csrf_token
auth_token
Functional cookiesWe use our own first-party cookies to provide the core functionality of the Services, such as authentication, load balancing, and preventing security exploits.As far as possible, these are session cookies.

You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use the Service.

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

Do not track

We do not support Do Not Track (“DNT”).

Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.

USES MADE OF PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing
To register you as a new customerIdentity Data, Contact DataPerformance of a contract with you
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to usIdentity Data, Contact Data, Financial Data, Transaction Data, Marketing and Communications Data(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms, this Privacy Policy, the Site or Services Asking you to leave a review or take a surveyIdentity Data, Contact Data, Profile Data, Marketing and Communications Data(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a surveyIdentity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, updates, reporting and hosting of data)Identity Data, Contact Data, Technical Data(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant Site and Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity Data, Contact Data, Profile Data, Usage Data, Marketing and Communications Data, Technical DataNecessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site and Services, marketing, customer relationships and experiencesTechnical Data, Usage DataNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to youIdentity Data, Contact Data, Technical Data, Usage Data, Profile Data, Marketing and Communications DataNecessary for our legitimate interests (to develop our Services and grow our business)
To enable you to apply to work for usIdentity Data, Contact Data, Financial Data, Technical Data(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated) and to enable you to apply to work for us

We will not sell or rent your personal data to anyone.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE OF YOUR PERSONAL DATA

Personal data we share with third parties. We may share your personal data with selected third parties, set out in our GDPR Policy. including:

Personal data we disclose to third parties. We may disclose your personal data to third parties:

INTERNATIONAL TRANSFERS

Our Services are global and your personal data may be stored and processed in any country where we have operations, our staff are located or where we engage service providers engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. This will involve a transfer your personal data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.

Processing of your personal data will involve a transfer of data to countries outside the European Economic Area (“EEA“), Switzerland or the UK.

We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy. In particular this means that your personal data will only be transferred to a country that provides an adequate level of protection (for example, where the European Commission or the UK Data Protection Authority, (“ICO”) has determined that a country provides an adequate level of protection) or where the recipient is bound by standard contractual clauses according to conditions provided by the European Commission or ICO.

Our Site and Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Site or Services from outside the EEA, Switzerland or the UK. This means that where you chose to post your data on our Site or within the Services, it could be accessed from anywhere around the world and therefore a transfer of your personal data outside of the EEA, Switzerland or the UK may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, all information you provide to us is stored on our secure servers. Any credit card information or payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site or Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your data transmitted to our Site or the Services. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Site and Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

YOUR RIGHTS

You have the right under Data Protection Law, free of charge, to request:

You can make a request in relation to any of the above rights by contacting us as set out at the end of this Privacy Policy. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of Data Protection Law. Occasionally it could take us longer, if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

DATA DELETION REQUESTS

We automatically and fully delete your data three months after you cancel your account and/or your account expires. The sole reason for holding onto the data for three months is to allow you a reasonable amount of time to export your data or to reactivate your account.

Upon request to support@featureupvote.com, we can delete data earlier.

MARKETING COMMUNICATIONS

DATA RETENTION

We retain personal data for as long as necessary for the relevant activity for which it was provided or collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

This will be for as long as we provide access to the Site or Services to you, your account with us remains open or any period set out in any relevant contract you have with us. However, we may keep some data after your account is closed or you cease using the Site or Services for the purposes set out below.

After you have closed your account for: (i) a period of 6 months for all free trial users; or (ii) a period of at least 3 months for all paying users, we usually delete personal data, however we may retain personal data for longer where reasonably necessary in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect of our relationship with you, to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to “unsubscribe” from further messages from us. We will retain some anonymised information after your account has been closed and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the Site or Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

COMPLAINTS

Our intention is to meet the highest standards when collecting and using personal data. For this reason, we take complaints we receive very seriously. We encourage users to notify us if they think that our collection or use of personal data is unfair, misleading or inappropriate. If you have any complaints about our use of your personal data, please contact us as set out at the end of this Privacy Policy or contact your local data protection supervisory authority.

For all EU individuals: The Spanish Data Protection Agency (Agencia Española de Protección de Datos) – AEPD.

For UK individuals: To be announced. If you wish to raise a question please contact this email address, quoting “Barbary Software SL” in the subject line.

AGE OF USERS

This Site and the Services are not intended for and shall not be used by anyone under the age of 16.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

CONTACT

Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to us by email: support@featureupvote.com.