Last Updated: 6 June 2023
We know that you care about your personal data and how it is used. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
The company behind the Chaptter application, and therefore collecting your Personal Data, is WEGLUE S.L.
Types of Data collected
Among the types of Personal Data that Chappter collects from you there are various types of data as indicated below.
Public Account Information
When you set up a Chaptter account, you provide us with some personal information that serves to identify you when you interact with other Chaptter users. These include your first name, last name, and a profile picture. These data will be available to other users, particularly to other users that have joined Groups (named “chapters”) in which you also participate.
Your first name and last name cannot be altered or modified after your first sign-in for security reasons.
Private Account Information
Additionally to your public account information, when you create a Chaptter account we require that you provide us an email address and an account password. These data will be used to identify you when you login to the application and will not be accessible to any other Chaptter user.
When you use Chaptter, you provide us with data regarding the content that you upload to the Service. These data include videos, pictures and comments that you upload to the platform, as stated in our Terms of Service.
Personal Content that you choose to upload to Chaptter may be accessible to other users with which you have shared the content, and these users may save that content, or create a copy, externally to the service.
In addition to the data that you provide us directly, we collect data about your usage of the Service, to understand how you access and interact with Chaptter. This includes, for instance, information about when you use the Service, for how long, and what particular actions you take when using the Service - such as when you create a chapter, upload a piece of content or post a comment. This information helps us provide the Service to you, learn how the Service is used, and identify and suggest ways we can make the Service more useful to you.
When you use Chaptter, we collect data about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android) to ensure the Service works as expected for you. This information may comprise the gathering of identifiers that may be unique to your device and the IP Address from which you connect.
How we use your data
Your Personal Data is collected fundamentally to allow Chaptter to provide our Services to you. We need to collect the data stated above so that our Service can, for instance:
Verify your identity and ensure that only you have access to your account.
Allow you to set up and manage groups of users, or to join or disconnect from groups set up by other users.
Allow you to share your Personal Content with other users in your groups, and to have access to Personal Content that other users have posted in those groups.
Exchange comments and messages with other users.
In addition to this, the data collected serves other Chaptter’s legitimate interests to operate and improve our Service, including:
Maintain, monitor and dimension our services and the supporting infrastructure.
Communicate with you to let you know about important novelties in our services, such as new versions or new features.
Improve our Service by customizing your experience based on your past usage or stated preferences.
Prevent fraud and detect behaviour that may constitute a breach of our Terms of Service.
Develop new services or features and optimize our service based on usage statistics.
Who has access to your Data
Access to your data by other users
Chaptter is a content storage and sharing application. This means that when you post content to a group (“chapter”) other users belonging to the same groups have access to your data. You have control over who can see your content, as indicated in the section “Control over your Data”.
You should bear in mind that new members in chapters will have access to any content posted on those chapters, including content that was posted before they joined.
Access to your data by third parties
Chaptter may share your information with third parties as indicated below.
With service providers and business partners, who perform services on our behalf or provide services and functionality.
With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
Comply with applicable law, rule, or regulation.
Detect and remedy potential breach in our Terms of Service.
Protect the rights and safety of other users, Chaptter or third parties.
Detect and resolve fraud or security concerns.
We may also share with third parties aggregated, non-personally identifiable, or de-identified information.
Device permissions for Personal Data access
Depending on your specific device, Chaptter may request certain permissions that allow it to access your device Data as described below.
By default, these permissions must be granted by you before the respective information can be accessed. Once the permission has been given, you can revoke it at any time. The exact procedure for controlling app permissions may be dependent on your specific device and software.
Please note that the revoking of such permissions might impact the proper functioning of Chaptter.
If you grant any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Chaptter.
Used for accessing the camera or capturing images and video from the device.
Used for accessing and recording microphone audio from the User's device, particularly while recording videos.
Camera Roll / Gallery permission
Used for accessing videos and pictures that the User may want to upload to Chaptter.
Push Notifications permission
Used for sending to you Notifications about what is going on in the Application (new messages, videos, etc.) and other relevant communications between Chaptter and you.
Control over your Data
Chaptter is equipped with a set of tools to empower you to control your data.
Download your Personal Content
You can download or share with other services and applications any videos and pictures that you have uploaded to Chaptter by using the appropriate functionalities in the Service.
Delete your Personal Content
You can remove your Personal Content by using the appropriate functionalities incorporated in our Chaptter service.
You can remove individual pieces of content, for instance, when you choose to remove a video or a picture.
You can also choose to delete your account entirely by using the appropriate option in our Settings menu. When you decide to delete your account, all your personal content will be automatically removed from the Service and made unavailable to other users. This covers your videos, pictures and comments.
As stated in the “How long we retain your data” section, when you delete your Personal Content, Chaptter may be obliged to retain parts of it for a longer period due to technical reasons, or whenever required to do so for the performance of a legal obligation or upon order of an authority.
Who can download or share your Personal Content
If you prefer that users belonging to certain of your chapters do not have the possibility to export, edit or share your Content (videos or pictures), you can indicate this circumstance by establishing the adequate Settings within the Service. Bear in mind that these settings will not impede that these users may bring your Content out of the application and possibly into the public domain through different means, for instance by capturing your Content while it is being displayed on their devices.
How long we retain your Data
Chaptter is a service intended to allow you retain and share memories of special moments that you have lived with other people. Therefore, your Personal Content, as well as your Account Information, may be stored for as long as your account is active and until you decide to delete it.
You can delete your Personal Content and your Account at any time. You can check the relevant information in the “Control over your Data” section below.
As for other Personal Data collected for the purposes of Chaptter’s legitimate interests or other legal basis different than the provision of the Chappter service to you, such data shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting us.
Chaptter may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn.
Once the retention period expires, Personal Data shall under normal circumstances be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Contacting you for Marketing purposes
We may contact you periodically by e-mail or push notifications to provide information regarding our products and services – to inform you for instance about new features of our App - and content that may be of interest to you. If applicable law requires that we receive your explicit consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your explicit consent.
If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or opt-out of receiving such communications via the Settings section of the Chaptter application.
Mode and place of processing the Data
Methods of processing
Chaptter takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
Your Data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Depending on your location, data transfers may involve transferring the your Personal Data to a country other than your own. To find out more about the place of processing of such transferred Data, you can check the ‘Data transfer abroad’ section containing details about the processing of Personal Data.
Exerting your rights
You may exercise certain rights regarding your Personal Data.
Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
Access you Data. You have the right to learn if your Personal Data is being processed by Chaptter, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected.
Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Personal Data. In this case, we will not process your Data for any purpose other than storing it. Note that this may impose a limitation on our ability to provide the service.
Have your Personal Data deleted or otherwise removed. You have the right to obtain the erasure of your Personal Data from us, as it has been already stated in the ‘Control over your Data’ section in this policy.
Receive your Personal Data and have it transferred to another controller. You have the right to receive your Personal Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means. In any case, Chaptter incorporates a number of mechanisms by which you can download most of your Personal Content yourself directly from the application, as stated in the ‘Control over your Data’ section in this policy.
Lodge a complaint. Depending on your country of residence, you may have the right to bring a claim before the competent data protection authority.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed as early as possible and always within one month.
European Union Residents
If you happen to be a resident at a European Union Member State, there are a few additional considerations that you ought to know.
Controller of your data
WEGLUE S.L. is the legal controller of your Personal Data. You can find contact details at the beginning of this document.
Legal basis of processing your data
Chaptter may process Personal Data relating to you if one or more of the following applies:
If it is necessary for the performance of an agreement between you and Chaptter (e.g. the provision of Services under our Terms of Services).
If it is necessary for the purposes of the legitimate interests pursued by us or by a third party.
If it is necessary for compliance with a legal obligation that we are subject to, or carried out in the public interest.
If you have given your consent for one or more specific purposes.
Data transfer from the EU and/or Switzerland
A number of our cloud service providers which provide data storage, database, messaging or similar services are located, or partially located, in the United States. Our Service is hosted by Amazon Web Services. Additionally, we use services by PubNub for real-time messaging and by Game Analytics for analytics collection.
Standard Contractual Clauses
Standard contractual clauses (SCCs) are written commitments between parties that can be used as a ground for data transfers from the EU to third countries by providing appropriate data protection safeguards. SCCs have been approved by the European Commission and can’t be modified by the parties using them. Such clauses have also been approved for transfers of data to countries outside the UK and Switzerland. We rely on SCCs for our data transfers where required. If you want to obtain a copy of the SCCs, you can contact us at email@example.com.
Your Personal Data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of Chaptter or the related Services. You declare to be aware that Chaptter may be required to reveal personal data upon request of public authorities.
How “Do Not Track” requests are handled
Chaptter does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.