Privacy Policy Facebook Messenger Bot

  1. Name and contact details of the data controller and of the company data protection officer

This privacy policy applies to data processing by the following controller:

Name: More United

Address: Dean Bradley House, 52 Horseferry Road, SW1P 2AF

Email: hello@moreunited.org.uk

Phone: 07739 393551

Data protection officer: Tabitha Morton

  1. Contact via Facebook Messenger Bot

We offer the possibility to contact us via Facebook Messenger Bot ("Facebook Chatbot"). The Facebook Chatbot is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). Information about Facebook Messenger Chatbot and the GDPR regulations of Facebook can be found here: https://developers.facebook.com/docs/messenger-platform and https://www.facebook.com/about/privacy/.

  1. Personal data collected via Facebook Chatbot

Contacting us via Facebook Chatbot requires a valid Facebook account so that we know who the source of the inquiry is and that we can respond to it. Facebook provides us – in case you give consent in contacting us via Facebook Chatbot – with your Facebook Page Scoped User ID and your Facebook account name (first name, last name). Further information/data such as email address, telephone number or text input can be provided voluntarily as a result of double opt-in. Facebook also provides us your page interaction’s data on the Facebook page connected to the system and administered by the Data Controller, and also, we record every interaction happening during a chat with you by our Messenger channel.

  1. We use this information/data in order to
  1. The data processing for the purpose of contacting us takes place under Art. 6 (1), sentence 1, point (a) of the GDPR on the basis of your voluntarily given consent.

You have the right to withdraw your consent at any time pursuant to Art. 7 (3) of the GDPR. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. This means that from that time on we are no longer allowed to continue the data processing based on that consent.

Your right to withdraw may be exercised at any time using the button "Unsubscribe" at the bottom of the Facebook Chatbot window or by sending an email to hello@moreunited.org.uk

Once you have withdrawn your consent, we will no longer collect personal data by use of the Facebook Chatbot, unless you have expressly consented to another use of your data or we have reserved the right to use such data in a different way that is permitted by law and about which we have informed you in this policy. Please note, that the withdrawal of consent will not affect the lawfulness of processing based on your consent before its withdrawal.

  1. The personal data processed by us with respect to the Facebook Chatbot will be deleted in accordance with the legal requirements.
  1. Newsletter

If you have expressly consented under Art. 6 (1), sentence 1, point (a) of the GDPR we use your email address to regularly send you updates our campaigns and/or our services by email.

We use the so-called double opt-in method for sending the newsletter. This means that we send you an email newsletter only after you have expressly confirmed to us that you consent to the sending of newsletters. We then send you a confirmation email asking you to confirm, by clicking a provided link that you wish to receive newsletters in the future.

By activating the confirmation link, you grant us your consent to the use of your personal data pursuant to Art. 6 (1), sentence 1, point (a) of the GDPR. When you register for the newsletter, we retain your IP address as recorded by your Internet service provider (ISP) as well as the date and time of registration in order to allow us to track a possible misuse of your email address at a later time. The data collected by us when you register for the newsletter are used exclusively for promotional purposes by way of the newsletter.

You can unsubscribe the newsletter at any time using the link provided in the newsletter. Alternatively, you are also free at any time to email your unsubscribe request to admin@moreunited.org.uk Once you have unsubscribed, your email address is immediately deleted from our newsletter distribution list, unless you have expressly consented to another use of your data or we have reserved the right to use data in a different way that is permitted by law and about which we have informed you in this policy.

  1. Disclosure of data

Your personal data are not transmitted to third parties for any purposes other than those specified in the following.

We disclose your personal data to third parties only if:

  1. Rights of data subjects

You have the right:

  1. Data processor and sub-processors

We use Datadat OÜ (Pärnu mnt 158/2-88, 11317, Tallinn, Estonia; registry number 14680412; VAT number EE102152445), url: winwith.me) as the data processor that operates the Messenger Bot-building software and the database connected to that. Datadat OÜ has a Facebook App (WinWith.Me) for the communication of the bot with Facebook as a platform, and this app had been approved by Facebook.

Datadat OÜ uses the Hetzner Cloud service to store and access personal data provided by data processor/subprocessor Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. The privacy policy of the firm is available at: https://www.hetzner.com/rechtliches/datenschutz/

Datadat OÜ uses the Cloud Functions for Firebase, the Firebase Realtime Database, the Cloud Storage for Firebase services to store and access personal data provided by data processor/subprocessor Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google usually operates these services from a Google server in the USA and stores the data there. Google is certified under the Privacy Shield agreement and thus provides a safeguard in adherence to European data privacy laws: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

  1. Data security

We apply appropriate technical and organisational measures to protect your data against accidental or deliberate manipulation, partial or complete loss, destruction or unauthorised third-party access. Our safety measures are continually improved in keeping with technological advances.

  1. Status of and changes in this privacy policy

This privacy policy is up to date as of November 2019. Changes in statutory or regulatory requirements can make it necessary to amend this privacy policy.