In general, any information and data which you provide to URBAN WATCH over the Website, or which is otherwise gathered via the Website by URBAN WATCH, in the context of the use of URBAN WATCH's services (“Services”) as better defined in the Section 3 below, will be processed by URBAN WATCH in a lawful, fair and transparent manner. To this end, and as further described below, URBAN WATCH takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.
1. Data controller and Data Protection Officer
To get in touch with URBAN WATCH’s Data Protection Officer, please contact: firstname.lastname@example.org.
2. Personal Data processed
When you use the Website, URBAN WATCH will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. URBAN WATCH may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to URBAN WATCH.
This information may be classified as “Personal Data” and can be collected by URBAN WATCH both when you choose to provide it (e.g., when you subscribe to the newsletter or participate in the contest) or simply by analysing your behaviour on the Website.
Personal Data which can be processed by URBAN WATCH through the Website are as follows:
a. Name, contact details and other Personal Data
In various sections of the Website – including, in particular, if you decide to create an account on the Website – you will be asked to submit information such as your name, phone / mobile numbers, e-mail address, date of birth, country of residence and address etc. When subscribing or signing up to receive Services, you might be asked to provide information as to your preferred mode of payment – PayPal, bank transfer or credit card.
In addition, whenever you participate in surveys and other promotions which may be available on the Website, as well as whenever you communicate with URBAN WATCH through the contact details provided in the Website or with Customer Service, URBAN WATCH may collect additional information which you choose to provide.
b. Job applications
c. Special categories of Personal Data
Certain areas of the Website (such as Message to Seller or Contact Form) include free text fields where you can provide URBAN WATCH with some information or needs, which you may use to communicate Personal Data.
Where these fields are completely free, you may use them to disclose (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation.
URBAN WATCH asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. As it is totally optional to provide this information, if you do, please mind that URBAN WATCH needs your explicit consent to process on sort of Personal Data. URBAN WATCH would stress the importance of providing your explicit consent to process this sort of Personal Data if you decide, nonetheless, to share it.
d. Other persons’ Personal Data
As mentioned in the previous section, certain areas of the Website include free text fields where you can write messages to URBAN WATCH. These messages may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify URBAN WATCH against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As URBAN WATCH does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to URBAN WATCH; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give URBAN WATCH this information.
e. Browsing data
The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While URBAN WATCH does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save from this last purpose, these data do not persist for more than 7 working days.
3. Purposes of processing
URBAN WATCH intends to use your Personal Data, collected through the Website, for the following purposes:
- To verify your identity and assist you, in case you lose or forget your login / password details for any of URBAN WATCH’s registration services, to allow you to consult your purchase history, by maintaining a registered user profile, to send you URBAN WATCH newsletter you subscribed for as a service and which contains only informative material, to send you any information you explicitly requested; to finalise your purchase order and deliver the products you may buy on the Website, to allow you to request a price quote or any info you may ask for, to find the retailer next to you and to provide any other Services which you may request (“Service Provision”);
- For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, banners instant messaging, through an operator, traditional mail, through URBAN WATCH’s official social media pages, regarding URBAN WATCH‘s products and services, as well as those of selected third parties (“Marketing”);
- For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services similar to those you have purchased or requested through the use of the Website (“Soft Spam”);
- To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services which URBAN WATCH believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
- For compliance with laws which impose upon URBAN WATCH the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
- To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
4. Grounds for processing and mandatory / discretionary nature of processing
URBAN WATCH’s legal bases for processing your Personal Data, according to the purposes identified in Section 3, are as follows:
- Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give URBAN WATCH your Personal Data for these purposes; however, if you do not, URBAN WATCH will not be able to provide any Services to you.
- Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to URBAN WATCH for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from URBAN WATCH). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Soft Spam: processing for this purpose is based on the interest of URBAN WATCH of sending you direct e-mail marketing communication regarding products and services similar to those you have purchased through the use of the Website. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from the URBAN WATCH), by opposing through the link provided at the bottom of all such communications.
- Profiling: processing for this purpose is based on your consent collected by means of the banner cookie and/or with a specific tickbox. It is not mandatory for you to give consent to URBAN WATCH for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
- Compliance: processing for this purpose is necessary for URBAN WATCH to comply with its legal obligations. When you provide any Personal Data to URBAN WATCH, URBAN WATCH must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
- Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
5. Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
- Persons, companies or professional firms providing URBAN WATCH with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of URBAN WATCH;
- Entities engaged in order to provide the Services (e.g., courier services, hosting providers or e-mail platform providers);
- Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
- Persons authorised by URBAN WATCH to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of URBAN WATCH);
- Other companies within the URBAN WATCH Group for internal administrative purposes, including the processing of clients' or employees' Personal Data; and
- Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
6. Transfer of Personal Data
Considering URBAN WATCH’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. URBAN WATCH implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information about it are available sending a written request to URBAN WATCH at the following address: email@example.com.
7. Retention of Personal Data
Personal Data processed for Service Provision will be kept by URBAN WATCH for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, URBAN WATCH may continue to store this Personal Data for a longer period, as may be necessary to protect URBAN WATCH’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing and Profiling will be kept by URBAN WATCH from the moment you give consent until the moment you withdraw the consent given and renewed at fixed intervals. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by URBAN WATCH, in particular as may be necessary to protect URBAN WATCH’s interests related to potential liability related to this processing.
Personal Data processed for Soft Spam will be kept until you object to such processing by means of the link provided at the bottom of all such communications.
Personal Data processed for Compliance will be kept by URBAN WATCH for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by URBAN WATCH for as long as deemed strictly necessary to fulfil the purposes for which it was collected.
8. Data subjects’ rights
Under the Regulation, you, as a data subject, are entitled to exercise the following rights before URBAN WATCH, at any time:
- Access your Personal Data being processed by URBAN WATCH (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
- Correct or update your Personal Data processed by URBAN WATCH, where it may be inaccurate or incomplete;
- Request erasure of your Personal Data being processed by URBAN WATCH, where you feel that the processing is unnecessary or otherwise unlawful;
- Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
- Exercise your right to portability: the right to obtain a copy of your Personal Data provided to URBAN WATCH, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
- Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent URBAN WATCH from processing your Personal Data; or
- Withdraw your consent to processing (for Marketing and Profiling).
Please note that most of the Personal Data you provide to URBAN WATCH can be changed at any time, including your e-mail preferences, by accessing, where applicable, the user profile you can create on the Website.
When requesting for the Services, you may have selected the means of communication through whom you desired the Marketing to be carried out (i.e. fax, phone, SMS, email, mail, social media). You may withdraw the consents for the Marketing through the different means of communication from the user profile, where applicable, by de-selecting the relevant options. You can also withdraw consent for Marketing via e-mail or object to Soft Spam by selecting the appropriate link included at the bottom of every e-mail message received. The same applies to the URBAN WATCH newsletter you receive as a Service.
Consent for Profiling via cookies may be withdrawn as described in Section 2.f or, if via tick box, by changing, at any time, the preferences of the user profile you can create on the Website.
Aside from the above means, you can always exercise your rights described above by sending a written request to URBAN WATCH at the following address: firstname.lastname@example.org.
In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful.