Txt2Plate LTD Privacy Policy

Last updated: 19/01/2024

Introduction

Please take a few minutes to read this Privacy Policy, so that you understand what data we collect, what we do with it and why, how we protect it and what are your rights in relation to this data.

In general, we collect data that allows us to provide you with an optimal experience while using our Services. This includes, for example, some basic benefits like allowing other users to see the name and picture you have chosen to show, in addition to other purposes outlined in this Privacy Policy.

Txt2plate LTD core features are secured with end-to-end encryption: messages, media sharing and linked devices.

TABLE OF CONTENTS

• How We Use Your Data
• The Data We Collect
• What Other Users Can See
• Data Retention
• How We Share Your Personal Data
• Your Choices and Controls
• Your Rights Related to Your Personal Data
• Third-Party Websites, Apps, Services and Back-Ups
• Data Security and Storage
• Changes to this Privacy Policy
• Contact Us

How We Use Your Data

At Txt2plate, we use your personal data to provide you with the best possible Service. This includes administering your account, customizing and improving the Service we offer, serving ads and marketing campaigns, providing you with support and for compliance and safety reasons. We explain below the purposes for which we collect and use your personal data, as well as the types of data we use for each purpose.

You can find here information regarding the purposes for which we collect and use your personal data.

Authentication and Account Administration:

Txt2plate uses different types of your personal data to create and administrate your Txt2plate account in order to enable you to register, log in, activate and use the Services. This includes, for example:

• To authenticate and verify your account, as well as to make sure you do not already have a Txt2plate account;
• To create your profile, customize your Txt2plate account according to the information you have provided (e.g. name or photo), and display such information as part of your profile when you use Txt2plate Services.

The types of data we will use for such purpose will mainly include (as detailed in the “Data We Collect” section above):

• Data provided or collected through registration & under your Txt2plate account, such as Identifiers, your photo and Vehicle licence plate number and user name;

Provide our Services - Communication & Content Features (messaging, etc.).

Txt2plate uses different types of personal data in order to operate, provide and deliver to you our Services, including communication features. This includes, for example:

• To enable you to send and receive messages,delete messages and report messages

The types of data we will use for such purpose will mainly include (as detailed in the “Data We Collect” section above):

• User Submitted Content.

Customer Service:

Txt2plate uses different types of personal data in order to provide customer service and customer support. This may include, for example:

• We will use your contact details to communicate with you, give you information about your account, and respond to your requests;
• We may use your contact history and correspondence with us for the purpose of improving our Services, training our support team as well as internal management operation.

The types of data we will use for such purpose will mainly include (as detailed in the “Data We Collect” section above):

• Data provided or collected through registration & under your Txt2plate account, such as Identifiers and your Vehicle licence plate number;
• Data we collect from your communications with us, including support, customer services and other inquiries.

Safety, Security & Fraud Prevention:

Txt2plate uses different types of personal data for security purposes such as fraud and spam prevention. This may include, for example:

• We will collect and examine URLs included in messages or messages, which were reported by other users, or were otherwise suspected to be unsolicited and using your device operating system authentication services;
• We may use automated decisions to close or restrict an account based on such data and other logic we have created for this, in order to protect other users and prevent recurring breaches. If your account has been blocked, you can contact our support at admin@txt2plate.co.uk

The types of data we will use for such purpose will mainly include (as detailed in the “Data We Collect” section above):

• Data provided or collected through registration & under your Txt2plate account, such as Identifiers;

Defend our Rights, Enforce our Policies & Compliance with Legal Obligations and Public Interests:

Txt2plate LTD may use and share different types of personal data, and depending on the circumstances, for the purpose of defending our rights and enforcing our polices, terms and agreements, where it is necessary to comply with legal obligations to which we are subject to and cooperation with regulators and law enforcement bodies (valid legal request by the appropriate laws in the country you use the app), as well as in very limited and rare circumstances, where we find it necessary and essential for the purpose of protecting your or third party's life safety and security as well as humanitarian purposes. This may include, for example:

• In the event of a dispute, claims and legal proceedings, and solely to the extent necessary for such purpose;
• We may record and log some of your actions, such as acceptance of our terms and polices, acceptance of certain offers, and notices;
• We will store an indication of your request to exercise your rights related to your personal data in order to be able to demonstrate compliance;
• We may store communication data in accordance with local laws;
• We may be required to provide authorities with information in compliance with criminal investigations laws applicable to electronic communications provider or otherwise applicable to us;

Authentication and Account Administration:

The Data We Collect

The operation and use of our Txt2plate App and Services involves collection of personal data, where the types of such data depend on the type of Service and interaction with us. For example, when you sign up for Txt2plater, you directly provide us personal data. We also automatically collect certain personal data from our users device. We explain which information we collect and how we collect it below.

The types of personal data collected through use of our Services, including App and website, are listed below. We note that, some types of personal data we collect are required for all Txt2plate Services (for example, your email), some are optional, and subject to your discretion (for example, your photo).We wish to clarify that we do not read your messages via Txt2plate (unless reported by a user).

Data provided or collected through registration & under your account or participation in Txt2plaes activities:

• Identifiers, such as:
• Your personal details, (e.g., name,), if you provided them;
• Your contact details (e.g., email address), if you provided them;
• Your account login details, such as your username and any of your passwords;
• Device identifiers, as described below.
• Your photo, if you provided it (e.g., any avatar).

User Submitted Content:

Data we collect from your communications with us, including support, customer services and other inquiries:

If you choose to contact us through any means of communications we make available, you may provide us with certain information such as your contact details (e.g., name, email, phone number, vehicle licence plate number) and other information you provide (mainly, related to the issue you wish us to address or resolve). We will further store our contact history and correspondence with you.

Non User Data:

Vehicle licence plate number as sent message from a user from Txt2plate, as saved on a Txt2plates user data base: We may process your vehicle licence plate number even if you are not a Txt2plate user, in the event that your vehicle licence plate number was included in our existing user database that has been provided to us. To allow users to find and communicate with their chosen vehicle licence plate number who are users or who are not users in a more efficient way, and solely for as long as a relevant Txt2plate user's account exists on Txt2plate. In the event you will become an active user, the new user whose vehicle licence plate number is in the user data base, will be notified that have received a new message.

What Other Users Can See

When you use our Services, other Txt2plate users can only see certain data about you, for example, user name or the content you voluntarily share, as we further detail and explain below.

Other users can see on Txt2plate the following data about you:

• Unless you have changed your settings:
• Your user name
• Your public posts: if you post information on our public spaces such as communities or channels, it may be searchable and available to anyone on Txt2plate. You can always delete your posts on those public spaces, but Txt2plate cannot control and is not responsible for what other users do with this information (e.g., store on their devices, publish on Txt2plate or outside of it, etc.), thus, we recommend you do not disclose your personal data through the content of your posts.

Data Retention

Accordingly, we only keep personal data as long as required to fulfil the purpose for which the data was collected, or, in some instance, where we have other necessities to retain the personal data, for example, where required by law. We explain below the criteria used by us to determine the retention of your personal data (meaning, for how long we store it and when we delete it, aligned with the type of data and purpose of collection).

The criteria used by us to determine Txt2plate's retention periods are as follows:r

• The type of personal data and purpose of collection - unless otherwise specified, we retain data as long as it is necessary and relevant for us to achieve the purposes for which the personal data was collected. For example:
• Personal data required to be retained in order to maintain your Txt2plate account and to enable you the use of Txt2plate Services – these types of data, including your User name, and Vehicle licence plate number, will be retained for as long as you maintain your Txt2plate account.
• Personal data you have voluntarily provided during registration or through your account - these types of data, including your photo, will be retained for as long as you maintain your Txt2plate account.
• The details of your communication with our customer support team will be stored for 10 years.

If you decide to delete your Txt2plate account, the communications with our customer support will be retained as detailed above.

All other types of data related to your Txt2plate account will be deleted, unless we are required to further retain the data, subject to the criteria detailed below. We may keep activity data on a non-identifiable basis to improve our Services. Your posts on channels and communities may remain available if you do not delete them. Please note that deletion of the App (i.e., uninstall the App from your device) will not immediately delete your account, but if you do not reinstall it within subsequent two weeks your account may be deactivated. Note that your account may also be deactivated if you do not log into Txt2plate for twelve consecutive months.

• Compliance with our legal obligations - we are required to retain certain types of data in order to comply with our obligations under applicable laws. For example, we need to retain transactions information to comply with tax legislation. In addition, we may retain certain types of personal data in the event we are required to do so subject to a binding legal request or a court order. Further, subject to EU Directive 2002/58/EC we are required to retain certain personal data (such as Vehicle licence plate numbers ) to convey messages.
• Dispute, claims and legal proceedings if you have a dispute with us, we may retain certain types of personal data as necessary and applicable to your claims, including any legal proceedings between us, until such dispute was resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods. In addition, in the event you request to exercise your rights, we will maintain the applicable correspondence for as long as needed to demonstrate compliance, and usually in accordance with applicable statutory limitation periods.
• Retention for Non-User Data - if you are not a Txt2plate user, and we process your data to enable txt2plate users to communicate with you via Txt2plate Services we will retain such data as long as it is relevant to Txt2plate users, or until you have requested us to stop processing your Vehicle licence plate number . You can request to Vehicle licence plate number and opt out here (admin@txt2plate.co.uk). Further, this information may be stored as part of our fraud program or in response to specific customer queries.

How We Share Your Personal Data

We share data with third parties, including trusted companies that help us provide our Services in compliance with strict data security and privacy practices. We may also share personal data in limited circumstances where we are required to do so under applicable law. You can find here information about the categories of such third-party recipients, as well as the purpose for which the personal data is shared with such third parties.

Your data is kept safe with us, but we do share your personal data with third parties we trust, solely.

Our Service Providers:

We share your personal data with our trusted service providers and business partners that perform business operations for us on our behalf (as data processors) and pursuant to our instructions. This includes the following types of service providers:

• Data storage providers, with whom we entrust the hosting and storage of our data;
• Customer support providers, who help us perform such functions as customer support and customer service;

Where we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary in order for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

Legal and Law Enforcement:

Subject to our strict data security and privacy practices and without compromising our end-to-end encryption, we may disclose certain types of your data, including, and depending on the circumstances, Activity Data, Identifiers and your Vehicle licence plate number, to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Txt2plate user to legal liability, and solely to the extent needed to comply with such purpose.

Your Choices & Controls

The personal data is yours - the choice is yours too on how to customize your Txt2plate experience. Txt2plate users enjoy certain choices and controls related to their personal data. We explain below the controls and choices provided by Txt2plate and how you may exercise them, including deletion of messages.

Txt2plate provides you with certain choice and controls you may exercise, related to your personal data, as follows:

• We enable you to delete your messages anytime, even after they have been sent.
• You can disable and enable the “Can Reply” button so that the recipient can not reply to your message.

Your Rights Related to Your Personal Data

Subject to local law and your interaction with Txt2plate, you may have certain rights regarding the personal data that Txt2plate collects about you. Such rights may include the right to know which types of data we collect and why we collect it (as we detail under this notice), the right to request rectification of your personal data, the right to request us to delete your personal data, the right to opt-out of certain data collection, the right to access your personal data, the right to withdraw your consent, as well as the right to lodge a complaint to a supervisory authority. We further explain below the operational meaning of each such right, as well as when and how you may exercise your right.

Txt2plate respects your ability to exercise certain rights with regards to your personal data collected and stored. In some areas and jurisdictions, such principal rights may include all or some of the following rights:

• The right to be provided with information about our data collection and privacy practices - including the sources from which we collect data, the purposes for which we collect and share data, the data we hold. This Privacy Policy describes our practices in detail using simple language. Everything you need to know is here. If you have more questions, feel free to contact our support team.
• The right to access your personal data - you may receive your profile data by contacting our support team.
• The right to request rectification the personal data we hold about you - if you believe we have the wrong data about you, or that your data is incomplete, feel free to change your personal data at any time through the profile settings on your Txt2plate settings on your mobile device. If you can't find what you are looking for, contact us.
• The right to erase your personal data - We will delete the data which we are not otherwise required to keep or is not necessary for the provision of the Service.
• The right to object to our use of your personal data (right to opt out) - you can object to the processing of certain forms of data by contacting our support. Explain your special circumstances. If you receive emails from us, you can always opt out on the bottom of the email, or by contacting our support.
• The right to receive your personal data in a usable electronic format and transmit it to an external party (right to data portability) will be available by contacting support.
• The right to withdraw consent - where we have collected or other process your personal data based on your consent and permissions, at any time, you have the right withdraw your consent.
• Right to non-discrimination.
• The right to lodge a complaint with your local data protection authority or attorney general, as applicable, and the right to appeal.

We provide you with the ability to independently exercise certain choices and controls in connection with your personal data - please see details under the “Your Choices” paragraph above. If you wish to further exercise your rights, please contact us as specified under “Contact Us” section below. We will contact you if we need additional information from you in order to honour your requests.

Third-Party Websites, Apps, Services

Our App may contain links to other third-party websites or you may access Apps from a third-party website. We may also allow certain functionalities through third-party services. We are not responsible for the data collection by such third parties, and their privacy practices and polices shall govern your personal data processed by them.

Third parties websites, apps and services:

If you access our Services and App from any third-party website, service or other digital source, or access any third-party site or service from our Services and App, note that, your use and the personal data collected by such third parties or provided by you in connection therewith will be subject to such third party's practices and we do not monitor, nor are responsible for the privacy practices of these third parties.

Data Security and Storage

At Txt2plate we take information security seriously and have strict security measures in place to ensure that your account and your personal data are safe. Here you can find information regarding the security measures we have in place.

We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data. We evaluate these measures on a regular basis to ensure the security of the processing.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time. If we do (except for minor tweaks), we will notify you via our App and website.

We may modify or update this privacy notice from time to time.

If we change this privacy policy (except for technical tweaks), we will notify you of the changes. Where changes to this Privacy Policy will have a fundamental impact on the nature of the collection or use of your personal data, or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights. The last modification date of this privacy policy will be reflected in the “Last Updated” header above.

Contact us

admin@txt2plate.co.uk

This Privacy Policy is reviewed regularly to ensure its effectiveness and relevance. Updates will be communicated to all relevant stakeholders.

Please read the Privacy Policy carefully before using the website or App.