Got it. Here is a fully adapted Privacy Policy for use on the Filter My Review’s website that:
- Keeps the original data protection and partner details intact
- Makes DNA SAAS LABS, LLC t/a Rate My Service (ratemyservice.io) the platform owner and data controller
- Positions Filter My Review’s as a brand or marketing partner only, with no responsibility for platform operation, data processing or policy compliance, except where the law will not allow that to be excluded
You should still have this reviewed by an attorney before publishing. This is a strong liability-shifting draft, but no text can guarantee you are fully shielded in every jurisdiction.
Filter My Review’s
Privacy Policy
Effective date: 2023/11/21
This Privacy Policy explains how DNA SAAS LABS, LLC t/a Rate My Service (referred to as “Rate My Service”, “we”, “us”, “our”) collects, uses and shares personal information when you access and use the online review platform and related services that are marketed and branded as “Filter My Review’s”.
1. Roles and responsibility
- Rate My Service is the owner and operator of the review platform, including the software, servers and databases.
- Rate My Service is the data controller for personal data processed in connection with the review platform and related services described in this policy.
- Filter My Review’s is an independent brand and marketing partner that promotes and provides branded access to the Rate My Service platform. Filter My Review’s does not own or operate the Rate My Service software or infrastructure and does not decide how the platform processes personal data.
To the maximum extent permitted by applicable law:
- All obligations, responsibilities and liabilities relating to the operation of the platform, compliance with this Privacy Policy and the handling of personal data processed in the platform rest with Rate My Service.
- Filter My Review’s is not responsible or liable for any data processing activities carried out by Rate My Service, any third party processors used by Rate My Service or any policy issues, disputes or claims arising from use of the review platform.
If Filter My Review’s collects any information separately for its own marketing (for example, an independent contact form that does not connect into the Rate My Service platform), that collection may be subject to a separate notice issued by Filter My Review’s.
2. Cookies
Like many businesses, we use cookies and similar technologies.
2.1 What cookies are
Cookies are small text files placed in your browser storage. They help us collect standard internet log information and visitor behavior information. When you visit our websites or platform pages, we may collect information from you automatically through cookies or similar technology.
For more about cookies in general, visit: https://allaboutcookies.org
2.2 How we use cookies
We use cookies in a range of ways to improve your experience, including:
- Keeping you signed in
- Understanding how you use our website and platform
- Protecting our website and platform from malicious activities such as automated registrations and bots
- Aggregating anonymous data to help us generate reports of usage such as geographic area, device type and browser type
2.3 Types of cookies we use
There are a number of different types of cookies. Our website and platform in particular use:
Functionality cookies
We use these cookies so that we recognize you on our website and platform and remember your previously selected preferences. These may include language and location. A mix of first party and third party cookies are used.
Aggregation cookies
We use these cookies to collect information about your visit, the content you viewed, the links you followed and information about your browser, device and IP address. We sometimes share limited aspects of this data with third parties for security purposes. We may also share online data collected through aggregation cookies with other GDPR compliant sub processors.
2.4 How to manage cookies
You can set your browser to not accept cookies. The site above explains how to remove cookies from your browser. If you disable cookies, some features of the website or platform may not function properly.
3. Privacy policy of other websites
Our website and platform may contain links to other websites. This Privacy Policy applies only to the Rate My Service operated website and platform that you access via Filter My Review’s. If you click a link to another site, you should read that site’s own privacy policy. We are not responsible for the privacy practices of other websites.
4. Information collected from other sources
We may collect limited data from public databases, marketing partners and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners and other third parties. Examples include:
- Social media profile information
- Marketing leads
- Search results and links, including paid listings such as sponsored links
5. How we use your information
In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations and or your consent.
We use personal information collected via our sites and platform for the purposes described below. We rely on one or more of the following legal grounds:
- Business Purposes: legitimate business interests
- Contractual: to enter into or perform a contract with you
- Consent: where you have given specific consent
- Legal Reasons: to comply with legal obligations
5.1 Specific uses
We use the information we collect or receive to:
Send you marketing and promotional communications
Legal basis: Consent or Business Purposes
We and or our third party marketing partners may use the personal information you send to us for our marketing purposes, consistent with your preferences. You can opt out of marketing emails at any time (see “What are your privacy rights” below).
Send administrative information to you
Legal basis: Contractual or Legal Reasons
We may use your personal information to send you product, service and feature information and or information about changes to our terms, conditions and policies.
Fulfill and manage your orders
Legal basis: Contractual
We may use your information to fulfill and manage orders, payments, returns and exchanges made through our sites.
Request feedback
Legal basis: Business Purposes
We may use your information to request feedback and to contact you about your use of our sites or platform.
Enforce our terms, conditions and policies
Legal basis: Business Purposes or Legal Reasons
We may use your information to help monitor, investigate and enforce compliance with our terms, conditions and policies.
Respond to legal requests and prevent harm
Legal basis: Legal Reasons or Vital Interests
If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. We may also use information to investigate, prevent or take action regarding potential violations of our policies, suspected fraud, security issues, threats to safety or illegal activities.
Other business purposes
Legal basis: Business Purposes
We may use your information for data analysis, identifying usage trends, determining the effectiveness of campaigns and to evaluate and improve our sites, products, services, marketing and user experience.
6. Will your information be shared with anyone
In short: We share information only with your consent, to comply with laws, to protect rights or to fulfill business obligations.
We may process or share data based on the following legal bases:
- Consent: where you have given specific consent for a particular purpose
- Legitimate interests: where processing is reasonably necessary for our business interests
- Performance of a contract: where we need to process data to fulfill a contract with you
- Legal obligations: where we are legally required to disclose information
- Vital interests: where disclosure appears necessary to protect vital interests of any person
6.1 Typical sharing scenarios
Vendors, consultants and other third party service providers
We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to that information. Examples include:
- Payment processing
- Data analysis
- Email delivery
- Hosting services
- Customer service
- Marketing efforts
We may allow selected third parties to use tracking technology on the sites, which enables them to collect data about how you interact with the sites over time. This may be used to analyze and track data, determine the popularity of certain content and better understand online activity.
Unless described in this policy, we do not share, sell, rent or trade your information with third parties for their own promotional purposes.
Business transfers
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or part of our business to another company.
Business partners
We may share your information with our business partners to offer you certain products, services or promotions.
6.2 Business partners and purpose of sharing
| Business Partner | Contact Information | Type of Data Used | Why Data Needs To Be Shared | Purpose of Processor |
|---|---|---|---|---|
| Google OAuth2 | Privacy: https://policies.google.com/privacy?hl=en – Contact: https://about.google/contact-google/ – Rate My Service use and transfer of information received from Google APIs to any other app will follow the Google API Services User Data Policy including Limited Use requirements | Name and email of contacts | To import staff members from the client’s Google company account so they can use the Rate My Service application for customer feedback via email signatures | To act as an authentication gateway to access client account information |
| Azure AD Microsoft OAuth2 | Privacy: https://azure.microsoft.com/en-gb/support/legal/privacy-data-management/ – Contact: https://azure.microsoft.com/en-gb/contact/ | Name and email of contacts | To import staff members from the client’s Office365 account so they can use the Rate My Service application for customer feedback via email signatures | To act as an authentication gateway to access client account information |
| Outscraper | Privacy: https://outscraper.com/privacy/ – Contact: https://outscraper.com/contact-us/ | Google company ID | To specify which Google company ID the reviews should be fetched from | To provide reviews for the chosen company ID |
| Stripe | Privacy: https://stripe.com/en-gb-us/privacy – Contact: https://stripe.com/contact | Name, surname, card credentials | To create a customer profile and link card credentials to the Stripe profile | To process payments |
| Mandrill or Mailchimp | Privacy: https://mailchimp.com/legal/ – Contact: https://mailchimp.com/contact/ | Email address, staff member name, data included in notifications such as customer feedback customer name, message, rating and customer reviews | To create and send emails | To act as an email server to send emails |
| Google Maps API | Privacy: https://policies.google.com/privacy?hl=en – Contact: https://about.google/contact-google/ | Name of Google company and or chosen company ID, URL, identifier, company rating average and review count | 1. To help the client determine and verify which Google company they want to receive reviews for. 2. To fetch reviews from the specified Google company using Outscraper | To provide an autocomplete list of relevant Google companies and related metrics |
| Tawk.to | Privacy: https://www.tawk.to/legal/ – Contact: https://www.tawk.to/contact-us/ | Name, email address | To create support tickets or start online chat sessions using Tawk.to | To provide real time user support and allow users to create support tickets |
| ReCaptcha | Privacy: https://policies.google.com/privacy?hl=en – Contact: https://about.google/contact-google/ | IP address, loaded resources including styles or images, user Google account information where applicable, behavioral information such as scrolling, mouse movement, clicks, time on forms and typing patterns | To protect the website from spam, abuse and to identify bots and malicious software | To protect the website and platform from spam, abuse and malicious software |
| Google Tag Manager | Privacy: https://policies.google.com/privacy?hl=en – Contact: https://about.google/contact-google/ | Aggregated data about tag firing that does not include user IP addresses or any measurement identifiers associated with a particular individual | To improve the customer website journey across different devices | To optimize tag deployment, reduce configuration errors and allow modification and deployment of tags from a web based interface |
7. How long we keep your information
In short: We keep your information only as long as needed for the purposes set out in this policy, unless the law requires a longer period.
We will keep your personal information only for as long as necessary for the purposes in this policy, unless a longer retention period is required or permitted by law for example for tax, accounting or other legal requirements. No purpose in this policy requires us to retain your personal information for longer than three years from the moment of last given consent, unless the law says otherwise.
When we have no ongoing legitimate business need to process your personal information, we will delete or anonymize it. If immediate deletion is not reasonably possible for technical reasons for example stored in backup archives, we will securely store it and isolate it from any further processing until deletion is possible.
8. Your privacy rights
In short: In some regions, including the European Economic Area, you have specific rights that allow you greater access to and control over your personal information.
In some regions you may have rights under data protection laws that include:
- The right to request access to and obtain a copy of your personal information
- The right to request rectification or erasure of your personal information
- The right to restrict processing of your personal information
- The right to data portability where applicable
- The right to object to certain processing activities
To make a request, use the contact details in the “How can you contact us” section. We will consider and respond to any request in accordance with applicable data protection laws.
If we rely on your consent to process your personal information, you may withdraw your consent at any time. This will not affect the lawfulness of processing that took place before withdrawal.
If you are resident in the European Economic Area and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
9. GDPR compliance statement
We respect and comply with the EU General Data Protection Regulation.
Some key ways we comply include:
Consent
We explain what you are consenting to clearly and ask that you explicitly consent to contact where required.
Breach notification
In the event of a personal data breach that requires notification, we will notify affected users without undue delay and, where feasible, within 24 hours of first becoming aware of the breach, in line with legal requirements.
Right to access
Users can request confirmation as to whether personal data concerning them is being processed, where and for what purpose. We will provide a copy of the personal data, free of charge, in an electronic format where required.
Right to be forgotten
Subject to legal obligations and balancing your rights with any overriding public interest, we may delete your personal data where you have requested this.
Data portability
We allow you to receive personal data concerning you in a commonly used and machine readable format and you may have the right to transmit that data to another controller.
Privacy by design
We implement appropriate technical and organizational measures to meet GDPR requirements and protect the rights of data subjects. We hold and process only the data necessary for our duties data minimization and limit access to personal data to those who need it to perform processing.
10. Ownership and control of platform data
For clarity:
- Rate My Service owns and operates the review platform and associated infrastructure.
- Rate My Service and its licensors hold all rights, title and interest in and to the databases and data sets created by and within the platform, subject to any contractual rights granted to clients.
- Filter My Review’s does not own, control or manage personal data stored within the Rate My Service platform and does not act as data controller for such data.
As between Rate My Service and Filter My Review’s, all responsibility and liability associated with the collection, storage, security, use and disclosure of personal data within the platform rest with Rate My Service, except to the extent that such allocation is not permitted by applicable law.
11. Updates to this policy
In short: We may update this policy as needed to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. The updated version will be identified by an updated “Last update” date and will be effective as soon as it is accessible. If we make material changes, we may notify you by a prominent notice on the website or by contacting you directly.
We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.
12. How can you contact us about this policy
For all questions, requests or complaints regarding personal data processed in connection with the Rate My Service platform which you access through Filter My Review’s, contact Rate My Service:
Email: [email protected]
Post:
DNA SAAS LABS, LLC t/a Rate My Service
11 Vlei Street
Durbanville
Cape Town
South Africa
7750
Data Protection Officer
If you wish to report a complaint or feel that your concern has not been addressed in a satisfactory manner, you may contact our Data Protection Officer:
Data Protection Officer: Dominic Meulemans
Post:
11 Vlei Street
Durbanville
Cape Town
South Africa
7750
If you need additional assistance after contacting our Data Protection Officer, you have the right to contact the data protection authority in your country of residence. For more information about member organizations, see:
https://edpb.europa.eu/about-edpb/board/members_en
13. Important note about Filter My Review’s role
Filter My Review’s is a brand and marketing channel for the Rate My Service platform. Filter My Review’s does not operate or control the platform code, hosting or data processing logic and does not decide why or how your personal data is processed inside the platform.
To the fullest extent permitted by applicable law:
- Rate My Service is solely responsible for the operation of the platform and for compliance with this Privacy Policy and applicable data protection laws in relation to platform data.
- All claims, disputes or legal issues arising from or related to the collection and processing of personal data within the platform are between you and Rate My Service.
- Filter My Review’s does not accept and expressly disclaims any responsibility or liability for any loss, damage, breach, dispute or claim arising from or connected to the Rate My Service platform, its policies or its data processing activities, except where such responsibility cannot be excluded under applicable law.
Last update: 2023/11/21