Profila | Privacy data sheet

Privacy data sheet

Privacy data sheet PDF

Privacy data sheet

PROFILA Privacy Data Sheet

This Privacy Data Sheet describes how Profila processes personally identifiable information (“personal data”)

Overview of Profila’s application

Profila’s application is consumer-to-business platform that allows for consumers to manage their personal data and interact with brands and organisations in a private and secure way (the “Profila App”).

Throughout this document, we have used the terms, Brands, Users and Profila, but also Categories, Moments, and Subscription Offers.

Here is a brief explanation of them:

Users – You, a natural person that uses the Profila App;

Brands – an individual, corporation, partnership, joint venture, limited liability company, governmental authority, unincorporated organization, trust, association, or other entity, that is offering product and/or services in a physical or digital environment somewhere in the world;

Profila – We, Profila GmbH, the Swiss company that offers the Profila App to You;

Categories – a category – e.g. Travel & Adventure, Fashion, Food and Drinks, Entertainment, Music, Home Improvement and many more – in which You can capture Your sentiments and preferences by including Moments or via picture-based questionnaires (or by including pictures of Your own via the Moments function of the App);

Moments – means a photo that You capture via the App, to which you can include a sentiment emoticon (good or bad), and that You can share with a Brand or that You can include in a Category;

Subscription Offers – means an offer from a Brand, to subscribe to a certain set of your data, which may include a part of your Personal Information, Categories, and/or Moments;

The following paragraphs describe Profila’s processing of personal data in connection with the delivery of the Profila App, the location and transfers of that data, and how it is secured in accordance with privacy principles, laws, and regulations.

Profila will use your personal data in compliance with the information in this Privacy Data Sheet. Note that this Privacy Data Sheet is a supplement to the Privacy Policy.

Personal Data Processing

The Profila App allows Users to:

self-educate on and manage their privacy rights (privacy education and rights management);
to manage and share their preferences and sentiments in relation to several categories (e.g. Travel – Fashion – Food)(Categories);
to interact and communicate with Brands and share their choices on (i) and (ii);

All personal data of Profila Users that is stored, used and processed by Profila is in accordance with Profila’s data access and stringent security controls process.

Here you can find an overview of certain Personal Data Categories and Personal Data that is processed by Profila when Users such as You use the Profila App, and the purpose for which we process such Personal Data:

Profila App functionality	Personal Data (categories) Processed by PROFILA	Purposes of Processing the Data
Account Registration	· Registration Information will include: · · First Name · Last Name · Email Address · Date of Birth (and Age) · Nationality · Place of residence · Phone number · Profila registration ID	We use Registration Information to: · Create your Profila account to provide access · Authenticate and authorize access to your Profila account · Provide you access to your personal Profila profile · Provide access to the functionalities of the Profila App · Send you communications and information of new Categories · Send you communications on other offerings and Profila events if you have opted in to receive them · Make improvements to the Profila App based on your feedback and suggestion · For triage to diagnose technical issues, update and general maintenance of the Profila App · Provide you support to use the Profila App · Process your request to alter or delete your Profila account
Personal Data under “My Profila”	· · Personal Data under “My Profila” may include: · · First Name · Last Name · Nickname · Date (or month) of Birth · Gender · Country of Birth · Country of Residence · Avatar image/Photo · Addresses (Country, State, City, Zip code, Street Name) · Phone number · Email Address · Social Media account · Profila registration ID · Languages ·	We use Personal Data under “My Profila” to: · Provide access to the functionalities of the Profila App · Display your User avatar/photo to yourself and to Brands when you accept Subscription Offers · Enroll in privacy awareness trainings chosen by you and exercise your privacy rights · Provide access to the surveys as part of the Categories and your scores in each of them, as well as the Category avatars based on your results · Request your feedback through surveys if you have opted in to provide feedback on our App · Send you communications and information of new Categories · Send you communications on other offerings and Profila events if you have opted in to receive them · Make improvements to the Profila App based on your feedback and suggestion · For triage to diagnose technical issues, update and general maintenance of the Profila App · Provide you support to use the Profila App Process your request to alter or delete your Profila account
Categories (and Category Quizzes)	· User Generated Information through Quizzes may include: · · Category name (e.g “Travel & Adventure”) · Survey name (e.g. “weekend getaway”) · Survey date · Survey results (e.g. “you are an ecological traveler that prefers backpacking”) · Category factsheet · Category avatar ·	We use User Generated Information to: · Provide support to you as needed · · Provide you access to your information in the Profila App, including the results of your own Category Quizzes. · Provide you access to the Category functionality of the Profila App, so You can find out what your preferences and needs are for different Category topics.
Moments	· User Generated Information through Moments may include: · · Certain personal information to identify who made the Moment · The picture, video, audio, or text file you recorded · File names · Date and time · Category in which it is saved (if any) · Brand that was tagged · Sentiment (good or bad)(if any)	We use User Generated Information to: · Provide support to you as needed · · Provide you access to your information in the Profila App, including each specific Moment. Provide you access to the Moments functionality; Allow you to share your Moment with a brand of your choice, or to add a moment to one of your Categories.
Subscription Offer (pending or accepted)	· Depending on what a Brand requests, a Subscription Offer may include: · · Personal Information (such as First Name · Last Name · Email Address · Address (Country, State, City, Zip code, Street Name)) · · Category information (e.g. Category factsheet, Quiz results, avatar) · Moments (picture or audio file; File names · Date and time etc)	We use Information requested (in case of a pending Subscription Offer) and collected (in case You accepted the Subscription Offer) to: · Send you alerts (the first time) and reminders (thereafter) that a Brand has send you a Subscription Offer · Allow you to accept the commercial and privacy terms of the Subscription Offer and enter into a subscription contract with a Brand Allow you to monitor pending and existing Subscriptions and Subscription Offers Allow you to cancel existing Subscriptions Allow you to exercise Your Data Subject Rights towards a brand Allow you to receive Brand Moments and respond to Brand Moments Allow you to receive your Consumer Share as part of the Payment from a Brand.
Data Subject Rights	Information necessary to send the Data Subject Access Right assertion (content of the rights, sender, recipients, date, time, and read receipts) · Personal information (email address, first name, last name)	We use User Generated Information to: · Provide support to you as needed in exercising your Data Subject Rights. · · Provide you access to your information in the Profila App, namely which data subject right you exercised towards which Brand (including the date, the name of the brand and name of the DSR). Send our an email to the Brand with the information you included in the Data Subject Rights (for the email template, see Annex 1 to the EULA). Provide you access to the Data Subject Rights functionality in the Profila App.
Financial Data	Financial data may include: The details of your Uphold account Commercial details of each subscription offer and subscription contract	We use your Financial data to: Link Payments made by Brand to your activity under a Subscription Contract. Pay you out your Consumer Share in accordance with the EULA (between yourself and Profila) and the Commercial Terms and Subscription Contract (between yourself and a Brand). Provide you with an overview of all payments we received and Consumer Share payments we paid out.

Profila App functionality

Personal Data (categories) Processed by PROFILA

Purposes of Processing the Data

Account Registration

· Registration Information will include:

· First Name

· Last Name

· Email Address

· Date of Birth (and Age)

· Nationality

· Place of residence

· Phone number

· Profila registration ID

We use Registration Information to:

· Create your Profila account to provide access

· Authenticate and authorize access to your Profila account

· Provide you access to your personal Profila profile

· Provide access to the functionalities of the Profila App

· Send you communications and information of new Categories

· Send you communications on other offerings and Profila events if you have opted in to receive them

· Make improvements to the Profila App based on your feedback and suggestion

· For triage to diagnose technical issues, update and general maintenance of the Profila App

· Provide you support to use the Profila App

· Process your request to alter or delete your Profila account

Personal Data under “My Profila”

· Personal Data under “My Profila” may include:

· First Name

· Last Name

· Nickname

· Date (or month) of Birth

· Gender

· Country of Birth

· Country of Residence

· Avatar image/Photo

· Addresses (Country, State, City, Zip code, Street Name)

· Phone number

· Email Address

· Social Media account

· Profila registration ID

· Languages

We use Personal Data under “My Profila” to:

· Provide access to the functionalities of the Profila App

· Display your User avatar/photo to yourself and to Brands when you accept Subscription Offers

· Enroll in privacy awareness trainings chosen by you and exercise your privacy rights

· Provide access to the surveys as part of the Categories and your scores in each of them, as well as the Category avatars based on your results

· Request your feedback through surveys if you have opted in to provide feedback on our App

· Send you communications and information of new Categories

· Send you communications on other offerings and Profila events if you have opted in to receive them

· Make improvements to the Profila App based on your feedback and suggestion

· For triage to diagnose technical issues, update and general maintenance of the Profila App

· Provide you support to use the Profila App

Process your request to alter or delete your Profila account

Categories (and Category Quizzes)

· User Generated Information through Quizzes may include:

· Category name (e.g “Travel & Adventure”)

· Survey name (e.g. “weekend getaway”)

· Survey date

· Survey results (e.g. “you are an ecological traveler that prefers backpacking”)

· Category factsheet

· Category avatar

We use User Generated Information to:

· Provide support to you as needed

· Provide you access to your information in the Profila App, including the results of your own Category Quizzes.

· Provide you access to the Category functionality of the Profila App, so You can find out what your preferences and needs are for different Category topics.

Moments

· User Generated Information through Moments may include:

· Certain personal information to identify who made the Moment

· The picture, video, audio, or text file you recorded

· File names

· Date and time

· Category in which it is saved (if any)

· Brand that was tagged

· Sentiment (good or bad)(if any)

We use User Generated Information to:

· Provide support to you as needed

· Provide you access to your information in the Profila App, including each specific Moment.

Provide you access to the Moments functionality;

Allow you to share your Moment with a brand of your choice, or to add a moment to one of your Categories.

Subscription Offer (pending or accepted)

· Depending on what a Brand requests, a Subscription Offer may include:

· Personal Information (such as First Name

· Last Name

· Email Address

· Address (Country, State, City, Zip code, Street Name))

· Category information (e.g. Category factsheet, Quiz results, avatar)

· Moments (picture or audio file; File names

· Date and time etc)

We use Information requested (in case of a pending Subscription Offer) and collected (in case You accepted the Subscription Offer) to:

· Send you alerts (the first time) and reminders (thereafter) that a Brand has send you a Subscription Offer

· Allow you to accept the commercial and privacy terms of the Subscription Offer and enter into a subscription contract with a Brand

Allow you to monitor pending and existing Subscriptions and Subscription Offers

Allow you to cancel existing Subscriptions

Allow you to exercise Your Data Subject Rights towards a brand

Allow you to receive Brand Moments and respond to Brand Moments

Allow you to receive your Consumer Share as part of the Payment from a Brand.

Data Subject Rights

Information necessary to send the Data Subject Access Right assertion (content of the rights, sender, recipients, date, time, and read receipts)

· Personal information (email address, first name, last name)

We use User Generated Information to:

· Provide support to you as needed in exercising your Data Subject Rights.

· Provide you access to your information in the Profila App, namely which data subject right you exercised towards which Brand (including the date, the name of the brand and name of the DSR).

Send our an email to the Brand with the information you included in the Data Subject Rights (for the email template, see Annex 1 to the EULA).

Provide you access to the Data Subject Rights functionality in the Profila App.

Financial Data

Financial data may include:

The details of your Uphold account

Commercial details of each subscription offer and subscription contract

We use your Financial data to:

Link Payments made by Brand to your activity under a Subscription Contract.

Pay you out your Consumer Share in accordance with the EULA (between yourself and Profila) and the Commercial Terms and Subscription Contract (between yourself and a Brand).

Provide you with an overview of all payments we received and Consumer Share payments we paid out.

3. Local Data Storage & Cross Border Transfers

The Profila App uses Microsoft Azure Cloud as a storage for all personal data that is collected through the use of the Profila App. Profila keeps personal data of consumers separated by region, in order to minimize de cross-border transfers of personal data.

These data centers are currently located in the following countries (data center locations may change from time to time and this Privacy Data Sheet will be updated to reflect those changes):

Location	Data center name
Europe and CH	Microsoft Azure Cloud in Switzerland
USA	Microsoft Azure Cloud in the USA
LATAM	Microsoft Azure Cloud in Brazil

If your organisation is situated outside of these 3 regions, please contact Profila to discuss local storage in different regions.

Profila uses EU standard Contractual Clauses as a transfer mechanism to enable the lawful use of data across jurisdictions.

4. Access Control

Profila can access personal data of Users stored on the Profila App as described in the table below.

Upon request by You, Profila will access the personal data only while troubleshooting, updating the Profila App components, managing the platform, or providing support to the Users.

Personal Data	Who Has Access	Purpose of Access
Account Registration Information	Profila	Processed in accordance with our Privacy Policy
	Profila Service Providers	Providing a functionality to Users as part of the App experience (e.g. Twilio for SMS authentication; SurveyLegend for Category Surveys)
	Brands	If you accept a Subscription Offer, to provide You with the services as detailed in such offer.
	Profila	Modify or delete Users’ information based on their request. Also used to provide Support and identify Improvement opportunities for the Profila App
Information included in a Subscription Offers (pending or accepted)	Profila	Processed in accordance with our Privacy Policy
	Brands	Processed in accordance with Profila General Data Protection Policy and any privacy terms that are part of the Subscription Offer to allow you to enter into a contract with a Brand

Packet Tracer Usage Information		Processed in aggregate only and in accordance with our Privacy Policy
User Generated Information (Moments, Categories)	Profila	Processed in accordance with our Privacy Policy
	Brands (after You accept a Subscription Offer or after you send a Moment)	To allow You to share a Moment with Brands, or to allow you to accept a Subscription Offer
	Profila Service Providers	Providing a functionality to Users as part of the App experience (e.g. Twilio for SMS authentication; SurveyLegend for Category Surveys)
Information on Data Subject Rights	Profila	Processed in accordance with our Privacy Policy
Information on Data Subject Rights	Brands	So that a Brand can see what data subject right You exercised towards them, and to allow a response to Your request.

5. Data Portability or User-Generated information and other Personal data

The Profila App allows Users to access, view or change all User-generated Information in their Profila account.

6. Data Deletion

Users can request deletion of personal data stored on by Profila by sending a request to privacy@profila.com or by exercising your “right to be forgotten” (to see all of your personal data deleted) or “right to rectification” (to see inaccurate date deleted or altered) via the Privacy Awareness dashboard in the App.

Profila endeavors to remove the personal data from its platform in a timely manner, unless the personal data is required to be retained by Profila for legitimate business purposes. There is no ability to undo this action once the personal data is removed.

7. Personal Data Security

Profila has adopted technical and organizational security measures to protect your personal data from unauthorized access, use, or disclosure as required by law. Additional information about our encryption architecture is summarized in the table and paragraphs below.

Personal Data Category	TYPE OF ENCRYPTION
Registration Information (excluding Passwords, discussed below)	Encrypted in transit and at rest
Passwords	Encrypted and hashed in transit and at rest
User-Generated Information	Encrypted in transit and at rest

8. Third-Party Service Providers (Sub-Processors)

Profila may share certain parts of User’s registration information, data subject rights asserted, Category-information, Moments and/or User generated information with service providers, contractors or other third parties to assist in providing or improving the Profila App or for sending Profila product and events related communications to those who have opted in to receive such communications.

The following services will help us keep the Profila App running by storing or processing your data via certain Service Providers:

Infrastructure & storage: Microsoft Azure; Mongo DB ; Azure Blob
Analytics: Microsoft PowerBi
Communication: Microsoft Dynamics; Twilio; SendGrid
Identity and authentication: Microsoft Azure; 0365 Identity; JWT
Payments & Financials: Stripe, Microsoft Dynamics, Uphold
ERP and financial management: Microsoft Business Central
Quiz in each Category: SurveyLegend

The data shared may include Member’s name and email address or aggregate statistics or anonymized data. All sharing of information is carried out consistent with the Profila Privacy Policy and we contract with third-party service providers that can provide the same level of data protection and information security that you can expect from Profila. We do not rent or sell your information.

If Users would like more information about the Third-Party Service providers that their personal data is shared with and the purposes for the same; they may send an email to privacy@profila.com with a Subject that includes, “Request for information about Profila App Third parties”. You can also exercise your “right to information” or “right to access” via the Privacy Awareness dashboard in the App.

9. Certifications and Compliance with Privacy Laws

The Profila App and its underlying processes is designed to meet Profila’s obligations under the EU General Data Protection Regulation (“GDPR”) and other privacy laws around the world.

10. Data Subject Rights

Know Your Rights! And Use them!

You have the right to access, rectify and erase your personal data as well as to restrict or object the processing of your personal data. Besides that, you have the right to data portability. You also have the right to withdraw your consent for receiving further electronic communications.

You can exercise these rights by sending an e-mail to our Data Protection Coordinator via the Data Protection Contact Point at privacy@profila.com and only insofar reasonably possible and allowed by applicable law, or via the Privacy Awareness dashboard in the App.

Can you complain? Yes!

Finally, we inform you that you have the right to lodge a complaint with the relevant Data Protection Authority should any of your rights be violated. For a list of all Data Protection Authorities per region, see:

For the sake of completeness your personal data will be processed in accordance with this privacy notice and with our Privacy Policy.

11. FAQs

Additional GDPR specific FAQs can be accessed via the “settings” page in the App.

Privacy data sheet PDF