Yappr, mobilne internetne storitve, d.o.o. (short company name Yappr d.o.o.),
Rusjanov trg 5, 1000 Ljubljana, Slovenija,
Company registration number: 7238835000
Tax identification number: SI 82178321,
- Yappr d.o.o. (hereinafter respectfully: “we”, “us” or “Yappr”) The processing of your personal data takes place in compliance with the General Data Protection Regulation („GDPR“) and the Slovene data protection act in its current form.
- Controller. The controller for the data processing within the meaning of the GDPR is Yappr. You can contact us via mail under our email address (firstname.lastname@example.org) or via our help center.
- Data Protection Officer. Our data protection officer within the meaning of the GDPR can be contacted under our email address or via our help center. Should you have any questions regarding the processing of your personal data, please do not hesitate to contact him/her.
- Yappr processes such personal data, that you as a user of the Services make available to us, for example by using our Services, and that others provide to us.
- The Yappr Application (“Application”) only requires the User to sign in with their Facebook account through “Facebok connect” or Google account. Application only obtains the first and last name (and possible nicknames or middle names), email address, gender, date of birth of the registered User through Facebook connect or Google account.
- By logging in through “Facebook Connect” or another social network, we may also receive personal information about you which is provided by such social network. Please check the policies of such social network in order to understand what information we receive.
- In addition, when you use Yappr certain information may be automatically gathered about your computer, mobile device, browser, operating system, geo-location or IP address, however such information are usually not personal data.
- Application will also store geolocation or GPS position of the User’s mobile device (for showing the user position on the map) for allowing the User to access and use most of the Yappr application geolocation connected services.
- For potential web shop or other inside application purchases, awards collections, prize games or similar, the Users would also, at their own consent have to provide other information such as:
- address, postal code, city, country
- phone number ( for the courier shipping the Product to you)
- Payment information: We use payment providers (e.g. PayPal, a.o.) to process payments. Although we do not store any payment credentials information ourselves, we store a payment ID number that is given out by the respective provider and can be allocated to a person by that payment provider.
- The following personal data we retrieve from external services (without being explicitly provided by the User):
- ip address
- language (based on the settings of the browser/mobile phone of the user)
- country (based on the ip address)
USAGE OF EXTERNAL SERVICES AND DATA TRANSFER FOR THIRD PARTIES
- Google Analytics
- Opt-Out. You can prevent the collection of data through the cookie concerning your use of the Products (incl. your IP-address) as well as its processing of this data by Google, by downloading and installing the following browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en.
- Anonymize IP. The Products use Google Analytics in conjunction with the option “_anonymizeIP()”. This means, IP-addresses are processed in a shortened form in order to prevent transmission of any personal data. Any connection with a specific person is therefore precluded and personal data immediately deleted.
- Purpose. Yappr uses Google Analytics to analyse and be able to constantly improve the use of Yappr Products. Through the statistics, Yappr is able to improve its services and make them more interesting for users and to optimize new features and products. In those special cases in which personal data is transmitted to the USA, Google is certified via EU-US privacy shield. The basis for the processing is Art 6 sec 1 subsec f GDPR.
- Webshop Fulfillment/Shipping/Tracking
- For the (partially) automated handling of Yappr online shop orders, Yappr transmits for the shipping required data to the carrier of choice. Yappr primarily works with UPS, Fedex and the Mail Service In certain countries or regions, Yappr uses dropship-services for faster and easier fulfillment of orders. In these countries and regions, Yappr will transmit required information (such as name, shipping-address, email-address and phone number) solely for the purpose of the fulfillment of the order. Yappr currently works with EasyPost, Shipwire and Amazon Fulfillment, but reserves the right to add additional providers in the future.
- For Apps on iOS and Android Yappr uses the services of Google Inc. The tools “Fabric” and “Crashlytics” allow Yappr to track and analyze technical issues and bugs that occur in our mobile apps and help us understand how our users are using our app. For this purpose, Fabric and Crashlytics processes mobile identifiers. For more information on Fabric and Crashlytics, click here.
- Payment Service Provider
- All payments to Yappr are handled by external payment providers (Such as Adyen, Paypal, Klarna, Amazon Pay,…). In order to capture payments through external payment providers, Yappr transmits the following – for the payment relevant – data to the payment service provider:
- E-mail address
- First Name, Last Name
- Address, Zip Code, City, State, Country (for Fraud Detection)
- Payment Data (e.g. Credit Card Number)
- Yappr never stores any Payment Data (e.g. Credit Card Number), but leaves this up to the carefully select payment providers who store your payment details securely.
- Customer Service Software
- Yappr uses the customer support software Zendesk, in order to manage and answer customer requests via email and via help.Yappr.com. All requests will be sent to, stored and processed by Zendesk. All personally identifying information sent through a customer support request will therefore be transmitted to Zendesk. Additionally, Zendesk stores the following information:
- Language (through automated language detection)
- Yappr offers its users of the website, the online-shop and in the Yappr GPS WebApp the option to Live-Chat with the customer service team. To accomplish this, the software Tawk.to is being used. All data being transmitted through the live chat, will be stored and processed by Tawk.to. Therefore personally identifiable data entered by a user will be transmitted to Tawk.to. Aside from data entered by the user, Tawk.to will automatically store the following data:
- Language (detected based on browser language)
- All personally identifying data are being processed by Tawk.to and are only used to solve customer support cases and support the customer in the Live-Chat environment.
- In order to send emails (aside from newsletters) Yappr uses the following external software and services:
- Mandrill (MailChimp Add-on)
- Amazon Simple Email Service (SES)
- For the usage of the above service, the customers E-mail-address, the language, Firstname and Lastname are being transmitted to the service provider. All personally identifying data are being processed by Mailgun, Mandrill and Amazon Simple Email Service and are only used to for sending automated and automatically triggered emails.
- Email Verification
In order to verify E-mail addresses Yappr uses the software QuickEmailVerification. This cloud based software only receives the E-mail address to process it upon automated request from Yappr.
- Performance/Service Quality Monitoring
- New Relic
To monitor performance and quality of apps and services of Yappr, Yappr uses the software and service “New Relic”. To allow detailed analysis and monitoring of Yappr systems, the IP-address as well as the language (based on the browser setting) of the customer is being transferred to New Relic. No other personally identifying data is being transmitted to New Relic.
To analyze user behavior on the website of Yappr, the software Mouseflow is being used. Mouseflow captures clicks, interactions with the mouse as well as information entered by the customers in any of the forms on the website. In order to secure the privacy of the customer, the recordings are being anonymized. Yappr will not be able to see personally identifying information through Mouseflow.
- Other services
- Beside the services mentioned above Yappr may uses additional services to ensure high quality of all the Yappr products (e.g. caching services to reduce the response time of requests). It might be the case that personally identifying data is transmitted to those services. Yappr pares the transfer of this data down to the minimum which is required for using the services. The external services process the data on behalf of Yappr and do not use the data for their own benefit. The transferred personal data are mainly IP addresses, but other data, such as their name, may also be processed.
- Yappr websites and apps use retargeting technologies. This allows us to display advertising on partner websites to customers who previously were interested in Yappr and/or visited the Yappr website.
- We are convinced that personalized and interest-based advertising is more interesting and relevant to our customers, compared to advertising without and relevance for the customer. Retargeting technologies analyze the information captured through interactions with Yappr (website, online-shop, apps) as well as through cookies, and displays advertising based on the users surf behavior online. More information about cookies can be found in section 5.
- Yappr uses remarketing services from Google Inc. (AdWords), Microsoft (Bing) and Facebook. Yappr remains the right to add additional remarketing providers.
- Affiliate Marketing
Yappr also works with Affiliate Marketing Services (Affilinet, Share a Sale, Zanox,…), who display advertising on partner websites. These providers can store data about your usage of the Yappr website and/or Yappr apps.
- The following personal related data is forwarded to the Affiliate Marketing Services:
- IP address
- country (as provided in the invoice and delivery settings)
- Additionally we forward the webshop order id to the Affiliate Marketing Services. This order number does not allow affiliate partners to infer additional personal information.
COOKIES AND PLUGINS
5.1. Cookies What are Cookies. The Website use ‘cookies’ – small text files that are placed on your computer, mobile device and/or stored by the browser. If the respective server of our Website is again accessed by the user, the user’s browser sends the afore received cookie back to the server. The server can evaluate the information received in this manner in various ways. Cookies cannot run programs or infect your computer/mobile device with a virus. Cookies can help to make websites more user- friendly and effective. They can, for example, be used in order to manage advertisements on the Website or to facilitate navigation on a webpage.
- What are the different cookie types we use? There are different types of cookies with different uses. Some are there just to allow you to browse the website and see certain features. Some give us an idea on your browsing experience, i.e. when you have trouble finding what you are looking for, so we can improve and make your future visit as pleasant as possible.
- Cookies set by Yappr are called “first party cookies”. Cookies set by parties other than us are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer or mobile both when it visits the website in question and also when it visits certain other websites. We use first party and third party cookies for several reasons.
- The most important cookies are the required cookies. They are essential and help you to navigate on the website and to use basic features. Then there are functionality cookies that enable you to save your shopping bag and to use other additional features like the live chat. The performance and analytics cookies we use to improve our website. Interaction cookies are used for you to interact with social media. Targeting cookies, advertising cookies and social media cookies capture your preferences in order to show you relevant ads outside Yappr sites. In addition, social media cookies may be used to track your activity over social media platforms.
- Required Cookies
- are essential and help you navigate, move around on the website and see certain features (e.g. these cookies make sure your basket is saved during all the steps of your checkout process). These cookies are required to enable core site functionality. These cookies are stored for the duration of your browsing session.
- Functionality and Analytics Cookies
- are there so we can give you an even smoother customer experience (e.g. these cookies help you to save and remind you about your shopping bag). These cookies allow us to analyse site usage so we can measure and improve performance. These cookies may be placed by us or a third party on our behalf (see our cookie opt-out tool) and are stored for the duration of your browsing session.
- Advertising and social media cookies
- will remember your product and buying preferences or assist marketing efforts in other ways. These cookies enable us to share data, such as what you like, with our advertisers, so the advertisement you see can be more relevant to your preferences (sometimes referred to as “targeting cookies”).
- help us to understand shopping behaviour of visitors. This enables us to keep improving our website, so shopping becomes easier and more pleasant, and to improve the marketing messages we send to our customers (sometimes referred to as “performance cookies”).
- What if you don’t like cookies? You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:
- Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete- manage-cookies
- Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
- Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
- Safari: http://support.apple.com/kb/PH5042
- Opera: http://www.opera.com/browser/tutorials/security/privacy/
- Note that you may visit http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to learn about the options that some of the third parties we work with offer for opting out of certain ad targeting activities. You will need to visit those websites from each browser and device that you would like to be covered by your opt-out. Because the opt-out tools may depend on cookies, you may need to visit these sites again to reinstate your preferences if you delete your cookies.
- YAPPR IS NOT RESPONSIBLE FOR THE USE OF, OR GUIDELINES REGARDING THE USE OF, PERSONAL DATA BY THIRD PARTY PROVIDERS.
- Users may recognize the respective plugins of third parties, e.g., by the respective logo or other respective characteristic typical for the respective social media-platform on our pages.
- If users do not want to have the respective social media-platform associate their visits on our site with their social media-account, users must log out from their social media- account.
WHY WE PROCESS DATA (PURPOSES)
- 6.1. Operating the Products. We process your Data to be able to provide you with a seamless user experience when using our products.
- Selling/Shipping Products. To sell and ship our physical products.
- Providing Services. To operate the Products and provide the services, including to
- authenticate your access to an account;
- track your pet’s location;
- manage detailed information about your pet
- show statistics about your pet
- Customer Support. To investigate, respond to your requests, and resolve complaints and service issues, e.g. to contact you about a question you submitted to our customer service team.
- 6.2. Business Needs. We process your Data to manage our business needs, but only as long as your rights and interests do not outweigh ours. This includes advertisements and general marketing.
- Performance. We process Data to monitor, analyse and improve the use of our Products and services. As well as protect the security or integrity of the Products as well as their performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services.
- Research and Development. We process data, including public feedback, to conduct research and development for the further development of our Products in order to provide you and others with a better, more intuitive and personalized experience, and drive membership growth and engagement in our Products.
- Marketing General. We process Data to market to you by delivering (tailored) marketing materials about Yappr products and online services or the products and services of Yappr.
- Advertising. We target and measure the performance of ads to registered users and visitors.
- Newsletter/Push Message Marketing. With your consent we will send you newsletters with information on pet related topics.
- Retargeting. You might see marketing messages (ads) on different platforms (e.g. Google, Facebook, …). In addition, other users who have similar traits to you on those platforms could see marketing messages on those platforms as well (i.e. Facebook Lookalike audience).
- 6.3. Compliance and Enforcement.
- Compliance. We process your data to comply with our obligations and to comply with all applicable laws and regulations.
NEWSLETTER & PUSH-NOTIFICATIONS
- Registration / Cancellation
- Yappr only sends newsletters in the following cases:
- The user decides to register for the Yappr newsletter through the website www.Yappr.com . In this case the registration is being done with Double-Opt-In. This requires an email to be sent to the user after registration to confirm the registration, in order to avoid registration of E-mail-addresses that are not valid or confirmed.
- Customers can at any point in time cancel the subscription of the Yappr newsletter. By unsubscribing, Yappr will not send any additional emails through MailChimp and will not have access to statistical analysis.
- A link to unsubscribe from Yappr newsletters will be at the end of every newsletter.
- Usage of E-Mail Information System „MailChimp“
- E-Mail newsletters from Yappr are being sent by MailChimp, an email distribution platform by Rocket Science Group (Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA)
- The E-Mail-addresses of all Yappr newsletter subscribers as well as additional data as described in this document will be stored on servers owned by MailChimp. MailChimp uses the provided information solely for the distribution and analysis on behave of Yappr. Additionally, MailChimp can use the information to improve it services, e.g. optimizing their technical infrastructure and setup, visualization of newsletters or for economical reasons to detect the region of where newsletter subscribers come from.
- MailChimp explicitly does NOT use the data provided, to contact any subscribers and will in no circumstance hand over the data and/or E-Mail-addresses to a third party.
- Statistical data analysis
- Newsletters contain a so called “Tracking Pixel” which allows for statistical analysis. This “Tracking Pixel” allows to track technical information (such as Browser Version, IP-address and the point in time the document was opened. This information is being used to improve the system and service of MailChimp based on technical data or user groups, by looking how often / how long, where (location guess based on IP-address) and when an email is being read.
- Part of the statistical analysis is the detection of whether an email has been read, opened and whether a link was clicked in the email. Technically this information can be correlated to a unique user, but it is neither Yappr’s nor MailChimp’s intention to track the behavior of individual users. The analysis simply helps Yappr understand the reading patterns of its users and to understand whether certain topics in certain emails are more or less interesting to our users.
- Yappr will also send you (based on you allowing this through the apps) push notifications through its mobile apps. Notifications will be related to Yappr products Yappr App usage and/or information about new Yappr products and services or special offers.
- You can disable push notifications for individual apps in your phone settings or uninstall the app to discontinue receiving push notifications.
SHARING OF PERSONAL DATA
- We transmit Data to third parties only, if this is necessary for the Purposes, due to a request from a national authority, due to a court ruling, required by law, necessary to investigate and defend ourselves against any third-party claims or allegations, exercise or protect the rights and safety of Yappr, our members, personnel, or others, or if you have consented beforehand. We attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Service Providers and other Third Party Services.
- We transfer your information to others, who help us to provide and improve our Products (e.g. maintenance, analysis, audit, payments, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. The list of our Service Providers / Third Party Service can be found in section 4.
HOW LONG WE STORE DATA
- We store your Data as long as you are a registered user of the Products. Beyond that, we only store Data, if it is legally necessary (because of warranty, limitation or retention periods) or otherwise required.
- 9.2. Account Deletion. If you decide to delete your account, all personal data we have about you will be deleted with the following exceptions:
- All data necessary for the fulfillment of contractual obligations or the observance of the statutory retention requirements by Yappr must not be deleted, but minimized to the extent required. An example of this is the retention of the country selected by the customer when activating the GPS tracker. This country is relevant for determining the tax rate that applies. For tax reasons, no deletion of the country selected by the customer takes place here.
- Data published by the customer on external services (for example, GPS routes shared on Facebook) are not revised by deleting the user account.
- Data which serve to uniquely identify a customer (eg e-mail address) is anonymised by the deletion so that it is no longer possible to infer the identity of the user.
- The personal data sent to us by a customer with the deletion request remains stored in our Customer Service Software (Zendesk). The data transmitted to Yappr in the course of this customer inquiry will not be further processed and will only be used to document the deletion request.
- A deletion request does not affect data, if the storage is legally necessary, for example for accounting purposes.
WHICH RIGHTS YOU HAVE
- 10.1. Exercise of Rights. To exercise the rights defined in Sections 10.2 to 10.8, please send a request via e-mail to our email address or via mail to our postal address.
- 10.2. Revocation of Consent. You can revoke the consent for future data processing at any time. However, this does not affect the lawfulness of Data processing based on the consent before the revocation.
- 10.3. Right of Access. You have the right to obtain (i) confirmation as to whether or not your Data is being processed by us and, if so, (ii) more specific information on the Data.
- 10.4. Right to Rectification. You have the right to obtain from us the rectification of inaccurate Data concerning you. In case the Data processed by us is not correct, we will rectify these without undue delay and inform you of this rectification.
- 10.5. Right to Erasure. Should you decide, you do not want us to process your data any further, please contact us via mail. We’ll delete your account and erase your data. Should mandatory provisions of law prevent such erasure, we will inform you.
- 10.6. Right to Data Portability. You have the right to (i) receive your Data in a structured, commonly used and machine-readable format.
- 10.7. Right to Object. You have the right to object at any time to the processing of Data for which our legitimate interests are the legal basis, including profiling based on those provisions.
- 10.8. Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority, if you think that the processing of Data infringes applicable law, especially the GDPR (in Slovenia Informacijski pooblaščenec).
- 11. FURTHER IMPORTANT INFORMATION
- 11.1. Legal Bases. Data protection laws regulate, that we are only allowed to collect and process your Data, if we have lawful bases for processing. The lawfulness of processing stems from your consent in such cases where you have given consent;
- the necessity for the fulfillment of your user contract, e.g. where Data is needed for a satisfactory use of the Product; or
- legitimate interests pursued by Yappr or a third party.
- Our legitimate interests include protecting you, Yappr, or others from security threats or fraud, complying with all applicable laws, managing and improving our business (e.g. customer service, reporting) including possible corporate transactions (e.g. M&A), enabling users to share their and connect via dog experiences, and express all pet related opinions.
- The following processing is based on the legitimate interests of Yappr:
- Processing of billing-relevant data to comply with the statutory provision of accounting (for example, determining the tax rate based on the country selected by the customer when activating a GPS tracker).
- Processing demographic data in aggregated form for creating reports that improve the company.
- Processing of e-mail address, delivery address, billing address and IP address to detect potential fraud cases.
- Processing the IP address to detect and prevent potential attacks on the Yappr software system.
- 11.2. Safety Measures. To avoid unauthorized access to Data and generally secure the Data, we apply the safety measures which comply with the latest technological developments.
- 11.3. Pictures. By uploading pictures, you confirm that other persons depicted in the pictures consent to the upload of the respective picture.
- 11.4. Usage of Minors. Users under the age of 18 are not allowed to transmit any personally identifying information to Yappr, without the consent of their legal guardian.