Last Updated: May 15, 2023
1. Introduction
1.1 Welcome to Discy, a website and online service built and owned by PROJECTSTHAT.WORK LTD. (referred to as ‘PTW’, ‘we’ or ‘us’ from here on), A company registered in England and Wales with company number 13429582.
1.2 PTW respects the privacy and personal information of Discy's users and members of our Discy community. This Privacy Policy applies to information we receive when you use our website or the Discy software (collectively, the “Service”).
1.3 We want to be transparent about how we collect, use, and share information about you. This policy is intended to help you understand i) What information we collect about you, ii) How we use the information we collect, iii) How we share information we collect, iv) How we store and secure the information we collect, v) How to access and control your information, vi) Other important privacy information
1.4 This Privacy Policy is an agreement between PTW and you, as the user of the Service. Please read our Privacy Policy carefully. By accepting our Privacy Policy during your subscription to the Service you indicate your consent to the use of your personal information in a manner described in this policy.
1.5 If you do not agree with this policy, do not access or use our Service or interact with any other aspect of our business.
1.6 We do not have a Data Protection Officer, but if you have any questions or feedback on our Privacy Policy or our practices, please send an email to tim@discy.ai
2. Key Definitions
2.1 Key terms are defined below, for ease:
(a) Service: means the functionality of Discy that you can reach by visiting and using our website at www.discy.ai and any of its subdomains (e.g. app.discy.ai). It allows you to create and share discovery projects, capture, organise and categorise your discovery content, and analyse your discovery content.
(b) Content: means any qualitative data, such as analysis categories, interview details, interview questions, survey data, comments, notes and quotes or any other content that you enter or upload to Discy.
(c) Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
(d) Data Processor: A Data Controller may appoint another organisation or person to conduct certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example.)
(e) Personal Information: in this privacy policy we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information which has been anonymised;
(f) Special Information: certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religious and similar beliefs, trade union membership, sex life and sexual orientation. It also includes genetic information and biometric information.
3. Details of personal information which we collect and hold about you
3.1 We collect and process different types of information from or through the Service. Some of this information will qualify as Personal Information. The legal basis for PTW’s processing of your Personal Information is primarily to be able to provide the Service in accordance with PTW’s Terms of Service. The processing is carried out in PTW’s legitimate interests, which are further explained in the “Details of How and Why we use Personal Information” section of this Policy. We may also collect and process information upon your consent, asking for it as appropriate.:
(a) Account Registration and Profile Information: We may collect personal and/ or business information that can be used to identify you when you register for our newsletter or to use our product. This may include your name, and email address. Once you create an account, you may personalize your profile by uploading a profile picture. We use this information to administer your account and provide you with relevant services.
(b) Single Sign-on Authentication: Users may login into our product with an account they hold with the provider of a Single Sign-On service. As authentication takes place directly with the respective single sign-on provider, we may receive a user ID confirming the user is logged in with the respective single sign-on proivder. The user's password with the single sign-on provider is neither visible to us, nor is it stored by us.
(c) Device Information: We may collect information about the device you use to access our product, including the hardware model, operating system, and version.
(d) Log and Usage Information: When you use our product, we may automatically collect certain information, such as your IP address, browser type, and access times. We may also collect information about your usage, such as the features you use, the pages or screens you visit, and the actions you take within the product.
(e) Inquiries and Other Communications. If you contact us through any form, we may collect your name, email address and any other personal information you choose to provide to us. We use this information to investigate your query, and to communicate with you. We may also use it to enhance the services we offer to our users.
(f) Messages and User Content. You may upload or transmit data or information through your communications with us, or your use of the Services (collectively, “User Content”). For example, you may post comments captured during an interview. User Content and any information contained in the User Content, is stored, and collected as part of the Services. We use the User Content to fulfil the reason why it was provided (i.e., post your comments), and to operate, improve, personalize, and optimize the Services.
(g) Embedded help videos. We embed help videos in our product to explain its key functionality. When you access these videos, your IP address may be processed by the third party provider we use to host these videos.
(h) Survey Information includes information submitted through surveys or the content of any testimonials.
(i) Payment information relates to the methods by which you provide payment to us [such as bank account details, credit, or debit card details] and details of any payments (including amounts and dates) which are made between us.
3.2 We do not collect or hold any special information about you.
4. Details of how and why we use personal information.
4.1 So that we can provide you with access to our product, we will need your personal information. If you do not consent to provide us with the required personal information, we may be unable to provide you with access.
4.2 We may use the information we collect for the following purposes:
(a) To provide and maintain the service provided by our product;
(b) To test, improve and monitor our product, or diagnose and fix technology problems;
(c) To personalise your experience using our product. We analyse how individuals use our product to customise and improve the product experience;
(d) To respond to your inquiries and requests. Including where we may need additional information to fulfil the request or respond to inquiries;
(e) To send you administrative messages and other information related to our product. Including to help maintain the safety, security and integrity of our technology assets, service and business;
(f) To send you relevant marketing and advertising communications, such as newsletters and special offers;
(g) To comply with legal or contractual obligations (including in relation to our Terms of Service). Including to prevent, investigate or provide notice of fraud or unlawful or criminal activity.
4.3 Our use of your personal information for certain legal reasons is set out in data protection law.
(a) Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
(b) Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms, or interests;
(c) Legal Obligation Reason: this is where we must use your personal information to perform a legal obligation by which we are bound; and
(d) Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.
4.4 Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time.
4.5 Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data, we are able to use this.
5. Details about who your personal Information may be shared with
5.1 We may need to share the information we collect about you in the following ways:
(a) With third-party analytics providers who help us analyse and understand how users interact with our product
(b) With law enforcement or other government officials as required by law or to protect our legal rights;
(c) With third parties which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser.
5.2 We do not sell or trade any of the personal information you have provided to us.
6. Use of Cookies
6.1 Cookies are text files that contain small amounts of information that download to your browser when you visit a site. The entity that places cookies on your browser can then read the information on the cookie it set. Cookies have various jobs, for example, remembering your preferences and letting you navigate between pages efficiently.
6.2 We use and allow certain other companies (for example, Bubble) to use cookies in our product. We do this to allow you to access and use the Services without re-entering your username or password, to allow you to return to your most recent session state, and to prevent tampering with your session.
6.3 We have categorised the use of cookies in our product based on the ICC UK Cookie Guide: https://www.cookielaw.org/media/1096/icc_uk_cookiesguide_revnov.pdf
(a) Strictly necessary cookies: These are essential for the product to deliver the feature you have requested, such as remembering you have logged in.
(b) Performance cookies: These collect information on how users interact with the product and enable us to improve how the product performs. For example, we use Hotjar and Google Analytics cookies to understand how visitors use our product and website to identify areas for improvement in user experience and user interface.
(c) Functionality cookies: These remember choices you make such as colour scheme and search parameters. We use these cookies to provide an experience more appropriate with your selections.
6.4 You can block cookies using the relevant settings in your browser e.g., deactivating the use of cookies. This may restrict the functionality of our product. You can find information at the following site on how to modify the cookies settings on some popular browsers: https://www.allaboutcookies.org/manage-cookies/
7. Security
7.1 We take reasonable measures to protect the information we collect about you from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security.
8. Your rights under the data protection law
8.1 Under data protection laws, in relation to your personal information, your rights are as follows:
(a) Right to request access: This is the right to obtain from us a copy of the personal information which we hold about you.
(b) Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
(c) Right to erasure: This only applies in certain circumstances. Where it does apply, you have the right to request us to erase all your personal information.
(d) Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
(e) Right to data portability: this right allows you to request us to transfer your personal information to someone else.
(f) Right to object: you have the right to object to us processing your personal information for direct marketing purposes.
8.2 You may opt-out of receiving promotional communications from us by following the instructions in those communications to unsubscribe, opt-out, or change your marketing preferences. If you choose to opt-out, we may still send you non-promotional communications, such as relevant administrative messages.
9. Data Retention
9.1 We will only hold your personal data for as long as is necessary. This is until you delete your account or otherwise for a limited period for us to fulfil the purposes for which we have initially collected it, unless otherwise required by law.
9.2 We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
(a) the data of deleted accounts are deleted from the production systems immediately after we process your deletion request.
(b) backups of data are kept for up to 30 days from the date of deletion;
(c) billing information is retained for a period of 6 years as of their provision to PTW in accordance with the United Kingdom’s accounting and taxation laws;
(d) information on legal transactions between Client and PTW is retained for a period of 5 years as of their provision to PTW.
10. Changes to this Policy
10.1 We may update this Privacy Policy from time to time. If we make material changes to this policy, we will post a revised policy on our website and notify you by email, or through other reasonable means. By continuing to use the Service after getting notified about the changes, you are expressing and acknowledging your acceptance of the changes. If you do not agree to the changes, please kindly unsubscribe from our Service. Else, the revised terms and policies will apply to you.
11. Contact Us
11.1 Please contact us with any questions or concerns about this Policy, your Personal Information, our use and disclosure practices, or your consent choices by email at tim@discy.ai
