GIRAFFE360 PRIVACY POLICY
Last Updated: 24 August 2020
1.
WHO WE ARE AND OUR APPROACH TO PRIVACY
1.1

Giraffe360 Limited ("Giraffe360", "we", "our", or "us") is committed to protecting and respecting your privacy.

1.2

We provide a service to real estate companies (our "Partners") that allows them to take high-dynamic-range images of properties, using Giraffe360 camera equipment, in order to create virtual tours, floorplans and other high quality photography, and make these available through their websites, apps and social media pages. We do this by automatically sending the images taken by the Giraffe360 cameras to our cloud-based production service that creates the 3D representations and other content of the captured properties for use and distribution by the Partner (the "Giraffe360 Service").

1.3

This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access and use our website at giraffe360.com, including any subdomains of our website (the "Giraffe360 Website"), subscribe to the Giraffe360 Service, or when a Partner uses the Giraffe360 Service to take images of your property.

1.4

If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details at the end of this Privacy Policy.

2.
WHO IS RESPONSIBLE FOR YOUT PERSONAL INFORMATION
2.1

Giraffe360 determines and is responsible for the uses of your personal information described in this Privacy Policy, meaning that we will be the controller of your personal information when we use it in these instances, including when you access the Giraffe360 Website.

2.2

We may also receive some personal information about you, such as pictures or layout of your property, when we provide the Giraffe360 Service to our Partners. We only do this on the instructions of our Partners, so the Partner collecting this information when using the Giraffe360 Service determines and is responsible for how we use such personal information, meaning that they will be the controller of your personal information in those instances.

3.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
 

Personal information you submit to us

3.1

We collect personal information that you submit directly to us, including information you provide when you fill in an enquiry form on the Giraffe360 Website, interact with us using our chatbot function, or communicate with us about our products and services.

3.2

We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.

3.3

The list below sets out the categories of personal information we collect about you, how we use that information and the lawful basis we rely on to process that personal information:

Contact information, such as your name, phone number, email address, the name of your organisation and the country that you live in. We use this information to communicate with you about our products and services and to respond to any queries, issues or concerns you have. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

Comments and opinions. When you contact us directly, we will record your comments and opinions. We will use your comments and opinions to address your queries, issues and concerns and improve our products and services. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

 

Personal information collected from our Partners through the Giraffe360 Service

3.4

When a Partner captures imagery using our Giraffe360 camera equipment we may collect personal information which is depicted within that imagery. We collect and use this personal information on the instructions of the relevant Partner in order to provide the Partner with the Giraffe360 Service.

3.5

We also use this information for our own internal purposes to improve the accuracy and quality of our camera equipment and our processing algorithms, and for marketing purposes. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely, to develop and improve our products and the Giraffe360 Service and to inform our marketing strategy.

3.6

We do not use this information for any other purposes, but this information may be publicly displayed if the Partner chooses to display the imagery created through the Giraffe360 Service publicly through their website, app or social media (the "Partner Service"). You should ensure that you read the privacy notice or policy applicable to any Partner Service you use to understand how your personal information may be used by the relevant Partner when they use the Giraffe360 Service.

 

Personal information we collect automatically

3.7

We also automatically collect personal information indirectly about how you access and use the Giraffe360 Website and information about the device you use to access the Giraffe360 Website:

Information about how you access and use the Giraffe360 Website. For example, the website from which you came and the website to which you are going when you leave the Giraffe360 Website, how frequently you access the Giraffe360 Website, the time you access the Giraffe360 Website and how long you use it for, the approximate location that you access the Giraffe360 Website from, and other actions you take on the Giraffe360 Website.

Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to access the Giraffe360 Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Giraffe360 Website through the device, your internet service provider or mobile network and your IP address.

3.8

We use the information we collect automatically to present the Giraffe360 Website to you on your device and to determine products and services that may be of interest to you for marketing purposes. We also use the personal information we collect from you to monitor and improve the Giraffe360 Website and business, and to help us to develop new features on the Giraffe360 Website.

3.9

The processing of the personal information we collect from you automatically is necessary for our legitimate interests, namely: to tailor the Giraffe360 Website to the user and to improve the Giraffe360 Website generally; to monitor and resolve issues; for marketing purposes; and for the detection and prevention of fraud.

3.10

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Giraffe360 Website and developing new products and features. We may also share such anonymised information with others.

4.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
4.1

We will store the personal information we collect for our own purposes for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

4.2

Our Partners may, however, ask us to store your personal information relating to the images captured through the Giraffe360 Service on their behalf for longer. Please refer to the privacy notice for the Partner Service you use to find out how long the relevant Partner may store your personal information.

5.
RECIPIENTS
5.1

As required in accordance with how we use your personal information, we may share your personal information with the following:

(a)

Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, customer relationship management, legal, or analytic services.

(b)

Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(c)

Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Giraffe360, its users or others.

6.
MARKETING AND ADVERTISING
6.1

From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services.

6.2

Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

6.3

We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

7.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
7.1

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers.

7.2

International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside of the EEA; these international transfers of your personal information will be made pursuant to appropriate safeguards, including:

(a)

ensuring that recipients or the country in which they are located are deemed by the European Commission to provide adequate protection for personal information; and

(b)

ensuring that transfers are subject to standard contractual clauses approved by the European Commission for the transfer of personal information.

7.3

We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.

7.4

If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy.

8.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
8.1

In accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:

(a)

Right of access. You have the right to obtain:

(i)

confirmation of whether, and where, we are processing your personal information;

(ii)

information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii)

information about the categories of recipients with whom we may share your personal information; and

(iv)

a copy of the personal information we hold about you.

(b)

Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c)

Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d)

Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e)

Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f)

Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

8.2

You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

8.3

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

8.4

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10.
OUR POLICY TOWARDS CHILDREN
 

The Giraffe360 Website is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

11.
CHANGES TO THIS POLICY
 

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

12.
NOTICE TO YOU
 

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

13.
CONTACTING US
13.1

Please contact support@giraffe360.com if you have any questions, comments and requests regarding this privacy policy.

13.2

This privacy policy was last modified on 24 August 2020.