Introduction

This policy, together with our Terms and Conditions and any additional terms of use incorporated by reference into the Terms and Conditions, applies to your use of:

• Platd mobile application software available on www.platd.co for view, available for download on Google Play or Apple App Store, once you have downloaded theApp onto your mobile telephone or handheld device.
• Any of the services accessible through the App that are available on Google plat orApple App store.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This App is not intended for children and we do not knowingly collect data relating to children.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

In a nutshell, this Privacy Policy sets out:

1. Important information and who we are
2. What personal information we collect about you
3. How we use your personal information and basis for such use
4. How we obtain your personal information
5. Who we share your personal information with cookies
6. How long we keep your personal information 
7. How we protect your personal information
8. Which countries we transfer your personal information to
9. Your rights regarding your personal information
10. Our marketing policy
11. Links to third party websites or apps
12. Children
13. Changes to this Policy

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1. Who we are

We are Platd, a food-focused social media platform. Platd is a registered trade name with the Registrar of Companies of the Republic of Cyprus, owned by Aristos Michaelides.

Platd is the controller and is responsible for your personal data(“we”, “us” or “our” in this policy).  

Aristos Michaelides is the owner of the registered trade name Platd andthe controller and responsible for your personal data ("we","us" or "our" in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices,please contact us:

• Full name: Aristos Michaelides
• Email address: ari@platd.co
• Postal address: 15 Panathineon street,Nicosia, 2333, Cyprus
• Telephone number: +35799812373

You have the right to make a complaint at any time to the Office of the Commissioner forPersonal Data Protection, the Cyprus regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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2. What personal information we collect about you

We only collect the most relevant, proportionate for each purpose and strictly necessary personal information from you in the course of our business when you use the App. We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity data
• Contact data
• Financial data
• Transaction data
• Device data
• Content data
• Profile data
• Usage data
• Marketing and communications data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. 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 App 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.

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3. How we use your personal information and basis for such use

Purposes for which we will use your personal data

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

• When we have your consent,
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

The firm shall not carry out any automated decision-making activities, including profiling, using your personal information.

Change of purpose

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

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

In case we need to collect any Special Categories of Personal Data we will ensure to take all measures to comply with all applicable data protection laws.

Change of Purpose

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.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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.

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4. How we obtain your personal information

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

• Information you give us. This is information you consent to giving us about you by filling in forms on the Appstore or the Platd website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Appstore, download or register theApp, signup or make an account with the App, subscribe to any of our Services, make an in-App purchase, share data via an App's social media functions, and when you report a problem with the App, or our Services. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit or use the App or the Appstore or the Platd website we will automatically collect personal data including Device,Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
• ·Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties not limited, but including analytics providers, such as Google, advertising networks, search information providers, and third-party app providers or an Appstore you use to install the App or purchase a subscription.

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5. Who we share your personal information with

We may share personal information the following categories of third parties as necessary:

• Service providers who provide IT, system administration services and customer screening services.
• Third parties to whom we outsource certain support services such as, without limitation, document processing and translation services, photocopying and document review, confidential waste disposal, IT systems and/or software and/or storage providers, IT Support service providers, document and information storage providers.
• Professional advisers including lawyers, bankers, auditors, insurers and other professionals who provide consultancy, banking, legal, insurance, corporate, administration and accounting services.
• Government or governmental agencies, regulatory authorities, courts and law enforcement agencies, registries.  We may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted.
• Appropriate parties in the event of emergencies.
• Advertising networks: to support and display ads on our App, and other social media tools.
• Third party service providers to assist us with client insight analytics, such as Google Analytics.
• Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you, or delivering documents related to a matter.

Please note the following:

• This list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide our services as effectively as we can.
• We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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6. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the Appstore or any other relevant services sites and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

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7. How long we keep your personal information

We will retain relevant personal information for five (5) years from the date of our Last Interaction with you and in compliance with our obligations under the EU General Data Protection Regulation, or for longer if we are required to do so according to our legal, regulatory and/or compliance obligations or professional indemnity obligations. We may then destroy such files without further notice or liability.

It is provided that in the event that you delete or remove the App or unsubscribe or terminate your subscription, and you cease to be a user and/or subscriber and/or customer of the App, you will be able, for, and within, a period of 30 days, to reactive your account connected with all the personal information you have provided. Our Last Interaction with you is placed upon the expiration of this 30-day reactivation period.  

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App fora period of 12-months then we will treat the account as expired and your personal data may be deleted.

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8. How we protect your personal information

We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with the applicable data protection laws and the EU General Data Protection Regulation.  We have also implemented appropriate information security policies, rules and technical measures to secure your personal information collected by us. Your personal information is saved in an encrypted form.

All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal information on our behalf,), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information, keep it secure and protect it.

Notwithstanding the generality of the above, all information you provide to us is stored on our or our chosen third-party providers’ secure servers. Any payment transactions that might be carried out by us or our chosen third-party provider of payment processing services will be securely executed. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Certain Services and/or theApp include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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

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9. Which countries we transfer your personal information to

In order to provide our services we may need to transfer your personal information to locations outside Cyprus.  This may entail a transfer of your information from a location within the European Economic Area (the “EEA”) to outside theEEA, or from outside the EEA to a location within the EEA.  For any transfer of data outside the EEA, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws and the EU General Data Protection Regulation.

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10. Your rights regarding your personal information

You have the following rights in relation to the personal information we hold about you. Please note that some of these rights will only apply in certain circumstances and some of them may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of confidentiality obligations.

• Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and certain other information about it;
• Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
• Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;

• Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
• Transfer: you may us to help you request the transfer certain of your personal data to another party;
• Objection: where we are processing your personal data based on legitimate interests (or those of a third party) and you may challenge this.  However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
• Automated. decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
• Consent: where we are processing personal data with consent, you can withdraw your consent.

If you want to exercise any of these rights, please contact us at +35725585811.

Again, please note that you also have a right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus, where you are habitually resident, or where an alleged infringement of Data Protection law has taken place.

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11. Our marketing policy

You have the right to object where we are processing your personal information for direct marketing purposes. This means you can opt-out from receiving direct marketing from us at any time. 

We may use the information you give us on the App or other means for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of the Platd application, recipes, other home cooks, developments in the Platd application, market insights and of our services.

You can opt-out of receiving direct marketing from us at any time.  You can do this by clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by contacting us at ari@platd.co.

You have the right to ask us not to continue to process your personal data for marketing purposes.

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12. Children

We do not knowingly collect information from children or other persons who are under 16 years old without the consent and acceptance by any of their parent and/or guardian. If you are under 16 years old, you may not submit any personal data to us without the consent and acceptance by any of your parent and/or guardian

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13. Changes to this policy

We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements.Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

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14. Links to third-party websites or apps

Our App, emailupdates and other communications may, from time to time, contain links to andfrom the websites or apps of others. The personal data that you provide throughthese websites or apps is not in any case subject to this Privacy Policy andthe treatment of your personal data by such websites is not ourresponsibility. 

You should consult the third parties’ PrivacyPolicy notices which will set out how your information is collected and processed when visiting those websites or apps, as we have no control over information that is submitted to, or collected by, these third parties.

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DESCRIPTION OF CATEGORIES OF PERSONAL DATA

• Identity Data:first name, last name, maiden name, username or similar identifier.
• Contact Data:email address.
• Financial Data:bank account and payment card details, billing address for execution of payment.
• Transaction Data:includes details about payments to and from you and details of in-App purchases.
• Device Data:includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use.
• Content Data:includes information stored on your Device, including login information, photos, or other digital content.
• Profile Data:includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data:includes details of your use of theApp, whether this is required for our own billing purposes or otherwise.
• Marketing andCommunications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.