Privacy & Cookie Policy

1. Introduction

1.1 This Privacy & Cookie Policy sets out how Slib Design Limited of 24 Holborn Viaduct, City of London, London EC1A 2BN (we, us) use your personal information. It affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy & Cookie Policy, do not use the Slibstream platform or provide any personal information to us. If you have any questions, you can contact us at support@slibstream.com.

1.2 We reserve the right to update this Privacy & Cookie Policy from time to time at our discretion. If we do so, the updated version will be effective as soon as it is accessible. However, if we determine that any of the changes are particularly significant, we shall notify all Registered Users by email. In any event, you are responsible for regularly reviewing this Privacy & Cookie Policy so that you are aware of any changes to it.

1.3 This Privacy & Cookie Policy applies to all users of Slibstream including users who have a Slibstream account (Registered Users) and users who wish to view content of a Registered User (a Follower).

1.4 We are the data controller of the personal information that you provide to us.

2. Collecting and using your personal information

2.1 Slibstream.com User Registration

We collect the following personal information in our database:

  • Slibstream User ID
  • Slibstream Username
  • Name
  • Email
  • Telephone

Non Personal Information: Time, time and marketing preferences.

Sharing: We only share this personal information as set out in Section 3 below.

Usage: We collect this information for the provision of the Slibstream service in order for Registered User to create their Slibstream account.

Data Life: We collect this information until the Registered User deletes their account.

User Access To Their Data: This data can be accessed from within a Registered User account.

2.2 Slibstream Creations On Slibstream.com

We collect the following personal information our database:

  • Slibstream User ID
  • Instagram Usernames of your existing followers whom you may want to access a particular Slibstream

Non personal information: Style preferences, Instagram hash tags and messages.

Sharing: We only share this personal information with the original source of the Information (Instagram API) for the provision of the Slibstream service, and otherwise as set out in Section 3 below.

Usage: We collect this personal information for the provision of the Slibstream service in order for a Registered User to create Slibstreams.

Data Life: We collect this information for a period of time necessary to continue the Slibstream service or until the Registered User deletes their Slibstream.

User Access To Their Data: This data can be accessed from the My Slibstreams section of a Registered Users account.

2.3 Log Files On Slib.co and Slibstream.com

We log the following personal information in our log files:

  • IP Address
  • Slibstream User ID
  • Web Browser Agent Information (Type, OS, Version & Language)

Non Personal Information: Time, date, action and page.

Sharing: We only share this personal information as set out in Section 3 below.

Usage: We use this information to safe guard our systems and prevent data breaches and malicious system attacks.

Data Life: We retain log files for as long as you are a registered user of Slibstream.

User Access To Their Data: Users do not have access to this data.

2.4 Slibstream Play Activity On Slib.co

We record the following personal information when someone accesses a Slibstream Play URL on Slib.co for the first time or it reloads (manually or automatically):

Stored In Our Database

  • IP Address
  • Slibstream User ID
  • Anonymised String Part of Which Contains The Instagram User ID (Hashed)
  • Longitude and Latitude
  • City e.g. London
  • Region e.g. England
  • Country e.g. United Kingdom
  • Browser Language e.g. en
  • Time Zone e.g. Europe/London
  • Date and Time e.g. day, week, month, year, hours, minutes and seconds

Stored Locally As Sessions & Cookies (Not Stored In Our Database)

  • Instagram User ID (Encrypted)
  • Instagram Access Token (Encrypted)

Sharing: We share your IP Address to perform a Geo Location look up to obtain: Longitude, Latitude and Geo Location Data. We share your IP Address with IP-API.com and otherwise as set out in Section 3 below.

Usage: We use your Longitude and Latitude to dynamically create heat maps of user activity around the World accessing Slibstreams. Other data such as is displayed in tabular form and this data can be downloaded as .csv. This data is available to Slibstream Registered Users whom have a paid subscription.

To Opt In To Anonymous Tracking: Tick the “I agree to anonymous tracking of my use of Slibstream as set out in the Terms of Use and Privacy & Cookie Policy” checkbox on the Slib.co Play URL form.

To Opt Out Of Anonymous Tracking: Do not tick the “I agree to anonymous tracking of my use of Slibstream as set out in the Terms of Use and Privacy & Cookie Policy” checkbox on the Slib.co Play URL form. If users opt out their data is not shared when they access a particular Slibstream on Slib.co during a session. Users need to opt out on every Slibstream they play, everytime they are asked.

Users Access To Their Data: Registered Users can access and delete their usage data. Followers invited to a Slibstream by a Registered User can access and delete their usage data by signing up for a Slibstream account and deleting their data here. They can then delete their account here if they wish.

2.5 Slibstream Registered User Activity On Slibstream.com

We use Google Analytics and Google Analytics cookies to monitor our marketing efforts. We do not share this data with third parties. We use it to monitor the success of our marketing activity.

2.6 Support Form / New Support Ticket Form

We record the following personal information in our database when someone submits a support ticket:

  • Slibstream Username
  • Slibstream User ID
  • Name
  • Email
  • Telephone

Non Personal Information: Data specific to the issue they are experiencing that they need assistance with. Documents uploaded specific to the support case a user is experiencing.

Sharing: We only share this personal information as set out in Section 3 below.

Usage: We collect this information to solve support issues and provide a high level of custom service to our customers.

Opt Out: Registered Users have the option not to contact us using the support forms. We provide support videos as auxiliary open support assistance.

User Access To Their Data: Registered Users can delete their data by closing their Slibstream account. They can access their support tickets here.

2.7 Slibstream.com Homepage Contact Form

We record the following personal information in our database when someone submits our general contact form:

  • Name
  • Email
  • Telephone

Non Personal Information: Date, time and data specific to their enquiry.

Sharing: We only share this personal information as set out in Section 3 below.

Usage: We collect this information to provide customer service to potential customers.

Opt Out: Users have the option not to contact us using the homepage contact form. We have an auxiliary Frequently Asked Questions section on our homepage to answer general questions openly.

User Access To Their Data: Registered Users can delete their data by closing their Slibstream account

2.8 Slibstream Subscription Purchase

We record the following personal information when a Registered User purchases a Slibstream subscription:

  • Slibstream Username
  • Slibstream User ID
  • Name
  • Email
  • Telephone
  • Billing Address (Street. City, Post Code, Country)
  • Billing Information (Card Details, Payment Information)

Sharing & Usage:

  • Paying by Card – We share your card details with WorldPay to carry out the payment process and fulfil your transaction.
  • Paying by Cryptocurrency (Not Etherium) – We share your payment details with Cyrptonator & GoURL to carry out Crypto Currency payment process and fulfil your transaction.
  • Paying by Cryptocurrency (Etherium) – We share your payment details with PayWithEther to carry out the payment process and fulfil your transaction.
  • Paying by PayPal – We share your payment details with PayPal to carry out the PayPal payment process and fulfil your transaction.
  • We also share this personal information as set out in Section 3 below.

Opt Out: Users have the option to use Slibstream without making a purchase.

User Access To Their Data: Registered Users can access and delete this data in their account.

2.9 Slibstream Parental Or Guardian Consent Form

We record the following personal information when a user signs up to Slibstream:

  • Parent & Guardian Name
  • Parent & Guardian Email
  • Parent & Guardian IP Address
  • Parent & Guardian Signature
  • Parent & Guardian Telephone
  • Child Instagram Username
  • Child Email

Sharing: We only share this personal information as set out in Section 3 below.

Purpose: We collect this information to obtain consent from Parents and Guardians of Registered Users who are between 13 and 16 years old.

User Access To Their Data: A copy of this data is emailed to the parent/guardian. Users do not have access to this data in Slibstream. Registered Users can delete their data by closing their Slibstream account.

2.10 Instagram

We share the following personal information with Instagram API for the provision of our service. This data may include:

Non Personal:

  • Instagram Hash Tags
  • Number of Photos
  • Instagram Access Token (Decrypted)
  • Order of Photos (Most Recent, Most Liked, Least Liked and Oldest)

Instagram API already houses this data, Slibstream sends this specific data to Instagram so that it can query the API and create Slibstreams.

Purpose: We collect this information for the provision to Slibstream service.

User Access To Their Data: Instagram users can access all their Instagram data in their Instagram.com user account.

3. Sharing your information

3.1 In order to operate the Slibstream platform, and to take payment from Registered Users, we may from time to time share your personal information with the following sub-contractors:

Our sub-contractors agree only to use your personal information as necessary, and in accordance with applicable laws.

3.2 We do not share personal information with third parties, except (a) to respond to legal requirements (including under the Data Protection Act 1998 as amended or replaced from time to time) or protect a third party’s rights, property, or safety; and (b) in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

3.3 We may also use information we collect on an anonymous basis to (a) customise, measure and improve our services, content and advertising; (b) better understand our users, diagnose and fix problems; and (c) on an anonymous basis, for research purposes and for our general business purposes.

4. Marketing

4.1 When you register with us, you will be offered the opportunity to sign up to our marketing list to receive marketing email messages from us. You can choose to no longer receive marketing emails from us by contacting us at support@slibstream.com or by clicking unsubscribe from a marketing email. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.

5. Where we hold and process your personal information

5.1 Some or all of your personal information may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA. You are deemed to accept and agree to this by using the system and submitting information to us.

5.2 If we do store or transfer your personal information outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Data Protection Act 1998 as amended or replaced from time to time.

6. Security

6.1 We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorised access and disclosure. The technology that we use and the security policies which we have implemented are intended to safeguard your information from unauthorised access and improper use. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise that your personal information or other content that you upload to the system will always remain secure.

7. Your rights

7.1 We hold any transactional data that you provide to us for as long as you are a registered user of Slibstream.

7.2 You have the right to obtain from us a copy of the personal information that we hold for you, and to require us to correct errors in the personal information that we process for you if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal information and we shall do so within 24 hours of such a request. To exercise these rights, or any other rights you may have under applicable laws, please contact us at support@slibstream.com.

7.3 Please note, we reserve the right to charge an administrative fee of £10 if you wish to obtain a copy of the personal information that we hold for you.

7.4 If you have any complaints in relation to this Privacy & Cookie Policy or otherwise in relation to our processing of your personal information, you should contact the Information Commissioner, see www.ico.org.uk.

8. Cookies

8.1. A cookie is a small file that asks permission to be placed on your browser’s memory or alternatively your computer’s hard drive. Cookies placed in your browser’s memory are called session cookies and cookies placed on your computer’s hard drive are called persistent cookies. Session cookies are deleted when you close your browser, while persistent cookies remain on your hard drive, even after closing your browser. Session cookies are generally used to improve the user experience when using a website. Persistent cookies are generally used to store user preferences, including the preference to keep a user signed in, between browser sessions.

Slibstream.com & Slib.co Cookies

** Indicates: Instagram data

8.2 Cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. You can delete cookies at any time or you can set your browser to reject or disable cookies although this may disable some of the functionality of the website.

8.3 We allow analytics companies, such as Google Analytics, to use tracking technologies to collect information about our users’ computers or mobile devices and their online activities. These companies analyse this information to help us understand how the website is being used. Unlike cookies, this tracking technology cannot be deleted. In order to recognise you, store your preferences, and track your use of the website, we may store your device IDs (the unique identifier assigned to a device by the manufacturer) when you use the website.

9. General

9.1 If any provision of this Privacy & Cookie Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

9.2 This Privacy & Cookie Policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.

 

 

Last updated: December 2017