COUNTERMARK PRIVACY POLICY




Wessex Technology Opto-Electronics Products Limited (we) are commited to protecting and respecting your privacy.


Scope of policy


This policy (together with our end-user licence agreement available when you download the App (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • Our COUNTERMARK® mobile application software (App) available on our site or via several third party application stores (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

  • Any of the services accessible through the App (Services).

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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Any words with capital letters which are not defined when you first see them are defined in the EULA.

For the purpose of the UK Data Protection Act 1998, the data controller is Wessex Technology Opto-Electronic Products Limited of Wellesley House, 204 London Road, Waterlooville, Hants, PO7 7AN, United Kingdom.



Information we collect from you


We will collect and process the following data about you:

  • Information you give us (Submitted information): This is information you give us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you search for our App or Service, register to use the App Site, download the App, subscribe to any of our Services or use the App and when you report a problem with the App, our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information, financial and credit card information, personal description and photograph.

  • Information we collect about you and your device: Each time you visit one of our Sites or use the App we will automatically collect the following information:

    • technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, ICCID (SIMID), GUID (Globally Unique Identifier ), the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, contact information and login information (Device Information);

    • Location information: We also use your Device’s location services to determine your current location when you read a Countermark. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location services on your Device and if you do so, you may not be able to read any Countermark;

    • Image information from the cameras: We collect images of scanned Countermarks which can identify the item carrying the Countermark and other information, for example where the item was purchased.

  • Information provided to us by Customers for Private Countermarks: Our Customer can designate a Countermark as “Private” allowing the data protected by the Countermark to be accessed by identifiable users / mobile phones. When our Customer does this they will provide us with the authorised user’s name, email address and phone number or similar data. This information is used by us to verify the identity of the person attempting to read the Private Countermark.

  • Association of Categories of Information: We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.



Cookies


We use cookies to distinguish you from other users of the App, App Site, Appstore or Service Site. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and Our sites. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.



Uses made of the information


The App does not display adverts from third parties. We will never use your information for the purpose of advertising. The App will normally provide information from our Customer who issues the Countermark, such as an image, Snippet text or link to a website they nominate.

We require our Customers not to submit content as Snippets which is offensive, illegal, immoral, prejudicial to health, in breach of third party intellectual property rights, infringes any person’s right to privacy or which contains any form of malware. However please be aware that we do not audit or control what data a Customer chooses to make into a Snippet and replace with a Countermark.

If you provide financial information such as credit card details, this is used only as a form of identity verification. We do not charge you for using the App.

We use information held about you in the following ways:

  • Public Countermarks
  • If you use the App to read a public Countermark, we will share anonymised Submitted, Device and Location Information with our Customer which issued the Countermark. No information which specifically identifies you will be provided to our Customer.

  • We may however provide our Customer with anonymous aggregate information about Users (for example, we may inform them that 100 women in a particular US state read the Countermark in any given month).

  • Private Countermarks

  • If you use the App to read a Private Countermark, we will share such of your Submitted, Device and Location Information with our Customer which issued the Countermark as is necessary to confirm your identify, location and device you are using in order to determine if you are authorised to retrieve the Snippet, text, data or hyperlink to which the Countermark relates.



  • Our customer’s use of information


    We provide your information to Customers strictly for the purposes set out above in Uses made of the information. However, we do not control or manage how Customers use your information and we accept no responsibility for our Customers' use of the information for any other purposes.

    Without prejudice to the foregoing, if you believe a Customer has misused your information, you can notify us in accordance with the Contact section below. We will pass on your concern to our Customer and we may, in our absolute discretion, agree to assist an investigation into any mis-use although we shall have no legal obligation to do so.



    Our own use of your information


    You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

    We will disclose your personal information to third parties:

    • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

    • If Wessex Technology Opto-Electronic Products Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

    • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request, in order to:

      • enforce or apply our Terms of Use and any other agreements with you or to investigate potential breaches; or

      • protect the rights, property or safety of Wessex Technology Opto-Electronic Products Limited, our Customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

    These permissions will only be activated during the Countermark read process.



    Where we store your personal data


    The data that we collect from you will generally be transferred to, and stored at, destinations, and processed by staff who work for us or for one of our suppliers, inside the European Economic Area (EEA). These staff will be engaged in the fulfilment of your request to retrieve a Snippet and the provision of support services. We may occasionally need to transfer data outside the EEA and have staff outside the EEA process it where this is necessary to ensure we can provide you with our services. You consent to us transferring your data outside EEA in these circumstances.

    Your consent to processing

    By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

    Cloud storage

    All information we hold about you is stored on secure servers managed and operated by world-class cloud services such as Microsoft Azure.

    If you have a password

    Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Inherent risk of internet transmission

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites and 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.



    Access to information


    The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

    If you believe that any information we hold about you is incorrect, incomplete or out of date, you may request us to update it by contacting us through the email or phone numbers displayed on our website, www.countermark.com.



    Changes to 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 SMS, by e-mail or when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.



    Contact


    Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us via the email displayed on our website at www.countermark.com.