Privacy Policy
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided below and it is important that you read that information.
The privacy policy (and other policies) of the organisation which has organised your access to ChatPro will also apply to the personal data processed on ChatPro – you should contact your organisation in order to understand their privacy and other policies which also apply to your use of ChatPro.
Before creating an account, you will be required to indicate your consent to our processing of your personal data (including your name, email address, username, password and device information) as described below.
How you can withdraw consent
Once you provide consent, you may change your mind and withdraw consent at any time by contacting us using the details at https://www.chatpro.co.uk/contact but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
ChatPro Limited (we) are committed to protecting your personal data and respecting your privacy.
Introduction
This policy (together with our App user agreement as set out at https://www.chatpro.co.uk/policies and any additional terms of use incorporated by reference into the user agreement, together our Terms of Use) applies to your use of:
the ChatPro mobile application software (App) once you have created an account using the App on your mobile telephone or handheld device (Device);
Any of the services accessible through the App (Services).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Where we are processing your personal data on behalf of the organisation you have joined ChatPro with, you will need to refer to that organisations privacy and other policies about how your personal data in message and call recording content etc. will be handled.
Services include one-way, two-way, individual and group messaging and calling. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users. The content of all messages and call recordings may be seen by the administrator of the organisation with whom your account is associated, and the organisation may carry out routine or random checks, accessing and monitoring of message and call recording content, frequency, recipient and sender details and other information to ensure that all users of ChatPro are using the system in accordance with the organisations safeguarding, privacy and other policies. Please speak to your associated organisation if you have any questions about this. ChatPro itself does not access or monitor message or call recording content.
Important information and who we are
ChatPro Limited is the controller and is responsible for your personal data (referred to as “ChatPro”, "we", "us" or "our" in this policy) in respect of your account creation information. Your associate organisation is controller in respect of all other personal data processed through ChatPro including message and call recording content, and that organisations privacy policy shall apply in respect of that personal data.
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Name: Mr H Serle
Postal address: ChatPro Ltd, Henleaze Business Centre, Bristol, BS9 4PN.
Email address: privacy@chatpro.co.uk
Telephone number: 0330 133 5278
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. Our ICO reference is ZA773784.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 12th February 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Please note that websites and any services from third parties who may be linked or accessible through ChatPro have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows (explanations are provided in brackets after the data categories):
Identity Data (your name, date of birth, profile picture)
Contact Data (your email address, the email address of a parent/guardian if you are under the age of 13, your mobile telephone number if you are an organisation administrator)
Device Data (type of mobile device, unique device identifier, mobile operating system, type of mobile browser)
Profile Data (your password)
We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
However, such personal data may be included within message and call recording content on your organisations’ networks. ChatPro will only be a processor in respect of such personal data and you should refer to your organisations’ policies and privacy manager for further information in this respect.
How is your personal data collected?
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Device and Profile Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, create an account subscribe to any of our Services, search for an App or Service, and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you use our App we will automatically collect Device Data. We collect this data using cookies and other similar technologies. Please see our Cookie Policy at https://www.chatpro.co.uk/policies for further details.
Information we receive from other sources including third parties. We will receive Device Data from analytics providers such as Google (based outside the EU). We may also receive your name, date of birth and email address from organisations of which you are a member (e.g. your school).
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
The section below “Glossary: Lawful Basis” tells you more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above.
External Third Parties as set out in the Glossary below.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Data security
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches.
Services include one-way, two-way, individual and group messaging. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data retention
Details of retention periods for different aspects of your personal data which ChatPro holds as a data controller are available in our Data Retention Policy at https://www.chatpro.co.uk/policies.
Your name, date of birth, message and call recording content and other data generated by your use of ChatPro will be retained by your associated organisation(s) for up to 12 months, in accordance with their respective Privacy Policies. If it is necessary for an organisation to retain messages, call recordings and associated data for longer than 12 months, this will be communicated to you by the organisation via its Privacy and Rules statement, which is displayed to you when you join its network, and can be viewed at any time by tapping the Information button in the Chats screen of your app.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 6-months then we will treat the account as expired and your personal data may be deleted.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise any of these rights at any time by contacting us at https://www.chatpro.co.uk/contact.
Glossary
Lawful Basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third Parties
External Third Parties
Service providers acting as processors or sub-processors based in the EEA who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers based in the UK who provide consultancy, legal, insurance services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.