You may be given the option to access or register for the City Carrier Service through the use of your user name and passwords for Platform, such as through the use of your Google account, or otherwise have the option to authorize an integrated Service to provide Personal Data or other information to the City Carrier. By using the City Carrier, You authorize the City Carrier to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information to use and disclose it in accordance with this Policy.
The Citycarrier may obtain information, including Personal Data, from third parties and sources other than the City Carrier Service, such as the City Carrier partners, advertisers, and Service Providers. If the City Carrier combine or associate information from other sources with Personal Data that the Citycarrier collect through the Citycarrier Service, the Citycarrier will treat the combined information as Personal Data in accordance with this Policy.
When You use the City Carrier Services, we may automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that You visit just before or just after You use the Service, the pages or other content You view or otherwise interact with on the Service, and the dates and times that You visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether You opened, clicked on, or forwarded a message. This information is gathered from all users.
We may also implement third-party content or advertising on the Service that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Service. Additionally, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about You through such third parties’ browser cookies, even when You do not interact with the button. Information collected through web beacons and buttons is collected directly by these third parties, and City Carrier does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.
- Data Controller and Data Processor
The City Carrier does not own, control or direct the use of any of the information stored or processed by You via Services. Only You or Service Providers are entitled to access, retrieve and direct the use of such information. The City Carrier is largely unaware of what information is actually being stored or made available by You to the Services Providers and does not directly access such information or data except as authorized by the User or as necessary to provide Services to the User.
City Carrier is not responsible for the content of the User’s Data stored on User’s servers (or its subcontractors’ servers) at the discretion of the User nor is the City Carrier responsible for the manner in which the User collects, handles disclosure, distributes or otherwise processes such information.
How the City Carrier uses the information it collects? The City Carrier uses information that it collects on the Users in a variety of ways in providing the City Carrier Service and operating the City Carrier business, including the following:
- The City Carrier uses the information that it collects on the Service to operate, maintain, enhance and provide all features of the City Carrier Service, to provide services and information that You request, to respond to comments and questions and otherwise to provide support to users of the Platform.
- The City Carrier uses the information that it collects on the Service to understand and analyze the usage trends and preferences of the Users, to improve the City Carrier Service, and to develop new products, services, feature, and functionality.
- The City Carrier may use User’s email address or other information that it collects on the Service (i) to contact You for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to your User’s Data posted on the Platform or (ii) to send communications, including updates on promotions and events, relating to products and services offered by the City Carrier and by third parties it works with. Generally, You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
- The City Carrier may use “cookies” information and “automatically collected” information the City Carrier collects on the Services to: (i) personalize the City Carrier Services, such as remembering User’s information so that User will not have to re-enter it during its visit or the next time the User’s visit the Service; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of the City Carrier Services and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track Users entries, submissions, and status in any promotions or other activities on the Platform.
When the City Carrier discloses information. Except as described in this Policy, the City Carrier will not disclose User’s information that the City Carrier collects on the Services to third parties without the User’s consent. The City Carrier may disclose information to third parties if You consent to the City Carrier doing so, as well as in the following circumstances: Any information that You voluntarily choose to include in a publicly accessible area of the Service, such as a public profile page, will be available to anyone who has access to that content, including other users;
The City Carrier work with third party service providers to provide website, application development, hosting, maintenance, and other services for the City Carrier. These third parties may have access to or process User’s information as part of providing those services for the City Carrier. Generally, the City Carrier limits the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and the City Carrier require them to agree to maintain the confidentiality of such information.
The City Carrier may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding the City Carrier Users’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Platform.
The City Carrier may disclose the User’s information if required to do so by law or in the good-faith belief that such action is necessary to comply with the local laws, GDPR or to otherwise cooperate with law enforcement or other governmental agencies.
The City Carrier also reserve the right to disclose User’s information that the City Carrier believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect the City Carrier or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend the City Carrier against any third-party claims or allegations, (iv) protect the security or integrity of the City Carrier Service and any facilities or equipment used to make the Service available, or (v) protect the City Carrier property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
Information about the City Carrier Users, including Personal Data, may be disclosed and otherwise transferred to an investor, acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
The City Carrier respects User’s privacy rights and provide Users with reasonable access to the Personal Data that Users may provide through the Platform.
Further, the City Carrier provide Users with:
Users have the right to ask City Carrier whether we process data about them, to have access to that data and in addition the following information:
- The purposes of the processing
- The categories of the personal data concerned
- The recipients, or categories of recipients, of the data, if any, in particular any third countries or international organizations
- The length of time that the personal data be stored for (or the criteria used to determine that period)
- The data subject’s rights to rectification or erasure of their personal data and restriction of, or objection to, its processing
- The data subject’s right to lodge a complaint with a supervisory authority
- Information about the source of the data, if not directly from the data subject
- Whether the personal data will be subject to automated processing, including profiling and, if so, the logic and potential consequences involved
- Where the data are transferred to a third country or international organization, information about the safeguards that apply
- The right to rectification
Where personal data is inaccurate, the Users have the right to request that it be corrected and incomplete personal data completed based on information they provide.
Also known as “the right to be forgotten”, the Users have the right to require City Carrier to erase personal data about them without undue delay where one of the following applies:
- The personal data are no longer necessary for the purpose for which they were collected
- Users withdraws consent and there is no other legal ground for processing
- User objects to the processing of the personal data
- The personal data have been unlawfully processed
- For compliance reasons, i.e. to meet the legal obligations of City Carrier
- The right to data portability
- User have the right to request that their personal data be provided to them in a “structured, commonly-used and machine-readable format” (GDPR Article 20) and to transfer that data to another party e.g. service provider. This applies to personal data for which processing is based on the User’s consent and the processing carried out by automated means.
Where feasible, User can also request that the personal data be transferred directly from our systems to those of another provider.
You may, of course, decline to share certain Personal Data with the City Carrier, in which case the City Carrier may not be able to provide to You some of the features and functionality of the Platform. You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the Platform. If You wish to access or amend any other Personal Data the City Carrier hold about You, or to request the City Carrier to delete any information about You that the City Carrier have obtained from the Platform, You may contact us at privacy@CityCarrier.com. Please note that while any changes You make will be reflected in active user databases instantly or within a reasonable period of time, the City Carrier may retain all information You submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where the City Carrier otherwise reasonably believe that the City Carrier have a legitimate reason to do so.
You may opt out from sending navigation information about your visit to the Site to Google Analytics by using the Google Analytics Opt-out page.
If You received commercial email from the City Carrier, You may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from the City Carrier, and any other promotional communications that the City Carrier may send to You from time to time, by sending your request to the City Carrier by email at privacy@CityCarrier.com. The City Carrier may allow You to view and modify settings relating to the nature and frequency of promotional communications that You receive from the City Carrier in Account functionality on the Platform.
Please be aware that if You opt-out of receiving commercial email from the City Carrier or otherwise modify the nature or frequency of promotional communications You receive from the City Carrier, it may take up to ten business days for the City Carrier to process your request, and You may receive promotional communications from the City Carrier that You have opted-out from during that period. Additionally, even after You opt-out from receiving commercial messages from the City Carrier, You will continue to receive administrative messages from the City Carrier regarding the Service.
City Carrier has no direct relationship with the Service Provider or third party whose Personal Data it may process on behalf of a User. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct its query to the User they deal with directly. If the User requests the City Carrier to remove the data, the City Carrier will respond to their request within thirty (30) days. In any event, the City Carrier will delete or amend any Personal Data that the City Carrier is storing if the City Carrier receive a written request to do so, unless the City Carrier have a legal right to retain such Personal Data. Any such request should be addressed to privacy@CityCarrier.com and include sufficient information for City Carrier to identify the User or third party and the information to delete or amend.
- Third-Party Services
The Service may contain features or links to web sites and services provided by third parties. Any information You provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. The City Carrier is not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Platform. The City Carrier encourages You to learn about third parties’ privacy and security policies before providing them with information.
- Privacy Settings
Although the City Carrier may allow You to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. The City Carrier are not responsible for circumvention of any privacy settings or security measures on the Platform. Additionally, the City Carrier cannot control the actions of other Users with whom You may choose to share your information. Further, even after information posted on the Platform is removed, caching and archiving services may have saved that information, and other Users or third parties may have copied or stored the information available on the Platform. The City Carrier cannot and do not guarantee that information You post on or transmit to the Platform will not be viewed by unauthorized persons.
- Data Security
The City Carrier follows to generally accepted industry standards to protect the information submitted to the City Carrier, both during transmission and once the City Carrier receives it. The City Carrier maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in the City Carrier possession. This includes, for example, firewalls, password protection and other access and authentication controls. The City Carrier uses SSL technology to encrypt data during transmission through public internet, and the City Carrier also employs application-layer security features to further anonymize Personal Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. the City Carrier cannot ensure or warrant the security of any information You transmit to the City Carrier or store on the Platform, and You do so at your own risk. The City Carrier also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of the City Carrier physical, technical, or managerial safeguards. If You believe your Personal Data has been compromised, please contact us at dataprotection@CityCarrier.com.If the City Carrier learn of a security systems breach, then the City Carrier attempt to notify You electronically so that You can take appropriate protective steps. The City Carrier may post a notice through the Service if a security breach occurs.
- Data Retention
The City Carrier only retain the information collected from You for as long as your account is active or otherwise for a limited period of time as long as the City Carrier need it to fulfill the purposes for which the City Carrier have initially collected it, unless otherwise required by law. The City Carrier will retain and use information as necessary to comply with the City Carrier legal obligations, resolve disputes, and enforce the City Carrier agreements as follows:
- billing information is retained for a period of 7 years as of their provision to City Carrier in accordance with the Estonian accounting and taxation laws;
- information on legal transactions between the User and City Carrier is retained for a period of 10 years as of their provision to City Carrier in accordance with the general limitation period set for civil claims in the Estonian General Part of the Civil Code Act.
There are a number of key general principles that adopted when considering record retention policy. These are:
- Records held in compliance with all applicable legal, regulatory and contractual requirements
- Records not held for any longer than required
- The protection of records in terms of their confidentiality, integrity and availability in accordance with their security classification
- Records remain retrievable in line with business requirements at all times
- Where appropriate, records containing personal data subject as soon as possible to techniques that prevent the identification of a living individual
- Underage Privacy
Protecting the privacy of young children is especially important. The City Carrier Services is not directed to children under the age of 18, and the City Carrier does not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If You are under 18 years of age, then please do not use or access the Platform at any time or in any manner. If the City Carrier learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then the City Carrier will take the appropriate steps to delete this information. If You are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Platform, then You may alert the City Carrier at privacy@CityCarrier.com and request that the City Carrier delete that child’s Personal Data from the City Carrier systems.
- Updates and Changes