Last modified: October 7, 2021
What does this policy cover
This Policy sets out how ACS collects and uses the information that we collect about you when you use the Setty Service. This policy also explains the choices that you can make about the way that we use your information.
Information we collect and its use
We collect the following types of information about you:
Information you provide us directly
Information we may receive from third parties
We may receive information about you from third parties. For example, if you link a third party account to the Setty App (i.e., Instagram) that third party may pass certain information about your use of its service to ACS. This information could include, but is not limited to, the user ID associated with your account (for example, your Instagram user identification), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Setty Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service. If you unlink your third party account, ACS will no longer receive information collected about you in connection with that service and such unlinking may affect your ability to use the Setty Service.
Information we collect from you automatically
We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including, but not limited to, your mobile device ID, the type of mobile device you are using, information associated with your Apple Store or Google Play account, and other information that assists us in improving the Service.
Log file information
Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Clear gifs/web beacons information
When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service. These web beacons do not collect personal or location information.
When you access the Service by or through a mobile device (including but not limited to smartphones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by ACS. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
How we use your information
We use the information we collect about you for the following purposes:
Providing you with the Service: We use the information that you provide us to provide the Service to you. This includes allowing you to log in to Setty, operating and maintaining the Service, giving you access to your photographs, and billing you for transactions that you make via the Service, if applicable. We also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site
For data analytics: We use information about you to help us improve the Setty Service and our users’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.
Customizing the Service for you: We use information you provide us and information about you to make sure that your use of the Service is customized to your needs.
To communicate with you about the Service: We use your contact information to get in touch with you and to send communications about critical elements of the Service. For example, we may send you emails about technical issues, security alerts, or administrative matters.
To promote and drive engagement with the Setty Service: We use your contact information to get in touch with you about features and offers relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences. You can opt-out of getting these communications as described below.
Customer service: We use information about you, information that you provide to our customer service team, information about your interactions with the Service to resolve technical issues you experience with the Service, and to ensure that we can repair and improve the Service for all Setty users.
For matters that you have specifically consent to: From time to time ACS may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.
Legal bases for processing information under the GDPR (for users in the EEA)
For Setty users in the European Economic Area (EEA) ACS processes your information in accordance with European laws and regulations such as the General Data Protection Regulation (GDPR). The GDPR governs how ACS may process your information, and the rights that EEA users have in relation to it. This means that ACS will collect and use your information only where:
It is justified because of a legitimate interest such as for research and development or marketing the Service (but only where our legitimate interest isn’t overridden by your interest in protecting your data).
You consent to us using your information in a certain way.
It is necessary for compliance with our legal obligations.
If you have consented to our use of your information you may withdraw that consent at any time. To withdraw, simply follow the instructions and link at the bottom of this page. Where we are using your information because of a legitimate interest to do so, you have the right to object to that use. However, if you do so it may mean that it is not possible for you to continue using the Service.
Sharing your information
We will not rent or sell your information to third parties outside ACS and its group of companies (including any parent, subsidiaries, and affiliates) without your consent, except as noted in this section:
Who we may share your information with
Some of the third parties that ACS may share your personal information with include providers who assist ACS with functions such as:
• Customer support and customer management;
• Email services; and
Who you may choose to share your User Content with
Any information or content that you voluntarily share with the public using the Service becomes available to the public, as controlled by any applicable privacy settings.
ACS may also share your information with third parties in certain circumstances, such as where:
• we are required to do so as a result of a court order, subpoena, or other legal requirement;
• we believe that it is necessary to protect you or ACS, such as where we consider that there is a need to investigate potentially fraudulent or criminal activity; or
• you have consented to our sharing it with a third party for a particular purpose.
In the event of any significant transaction or matter involving ACS or any of its related entities or divisions including, but not limited to, a sale, merger, financing, re-organization, liquidation, or insolvency, other parties to the transaction and their professional advisors may need to have access to ACS’s customer lists and various databases as part of the due diligence process. In this event, ACS would only provide such access under terms of a strict confidentiality agreement. Also, upon completion of the transaction or event, your personal information would be transferred to the ACS successor-in-interest to be used only for the purposes for which it was collected. If we are able to provide advance notice to you, we will do our best to do so.
We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties engaged to assist ACS with its business operations.
Ads on Setty
Setty is an ad-free platform. If that changes you will be notified and provided with an opportunity to discontinue use of the Service.
How we transfer, store and protect your data
Cross-border transfers of information (for users in the EEA)
ACS is based in the United States and, regardless of where you use the Service, the information collected as part of that use may be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using the Service, you consent to this collection, transfer, storage, and processing of information to and in the United States in accordance with the foregoing.
Keeping your information safe
ACS cares about the security of your information and uses appropriate safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from ACS, at all times. However, ACS cannot ensure or warrant the security of any information you transmit to ACS or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Setty Service, such as social networks. ACS is not responsible for the functionality or security measures of any third party.
Compromise of information
In the event that any information under our control is compromised as a result of a breach of security, ACS will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Your choices about your information
You control your account information and settings.
You may update your account information by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at hello AT setty DOT app.
California Do Not Track Disclosure. ACS does not have a mechanism in place for responding to browser “do not track” signals or other similar mechanisms used to limit collection of information for use in online behavioral advertising.
Opting out of collection of your information
Rights in respect of your Information
The laws of some countries grant particular rights in respect of personal information. Users in those jurisdictions may have the right to:
• Request a copy of your information;
• Request that we correct inaccuracies relating to your information;
• Request that your information be deleted or that we restrict access to it;
• Request a structured electronic version of your information; and
• Object to our use of your information;
Should you wish to make a request in respect of your personal information please contact us at hello AT setty DOT app.
In some circumstances ACS may not be able to comply with a request that you make in respect of your personal data. For example, we may not be able to provide a copy of your information where it infringes on the rights of another User. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared your information with third parties, such as by publishing a design on a third party’s website. In that case ACS will not be able to delete the information, and you will need to contact that third party directly.
Special Provisions For Users Residing In California
If you are a California resident, you have the right to request information from us regarding the manner in which ACS shares certain categories of personal data with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
• the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed
This information may be provided in a standardized format that is not specific to you. Please direct these inquiries to hello AT setty DOT app and indicate “Request for California Privacy Information” in the subject.
How long we keep your User Content
Following termination or deactivation of your User account, ACS may retain your profile information and User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, ACS may retain your information for the purpose of comply with its legal and audit obligations, and for backup and archival purposes.
ACS does not knowingly collect or solicit personal information from children under the age of 13 and the Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at hello AT setty DOT app.
Links to other websites and services
Changes to This Policy
We reserve the right to update or modify the Service or this Policy at any time and from time to time without prior notice. Any revisions to this Policy will be effective upon posting. You should review this Policy periodically to ensure you are aware of any changes. If you object to any changes to this Policy, you must cease using the Service. Please review this Policy periodically by visiting the Website or App. This Policy was last updated on the date indicated at the top of this page. Your continued use of any of our Service after any changes or revisions to this Policy indicates your agreement to the terms of the revised Policy.
How to contact us