Updated on 20 May, 2020

Introduction

This privacy policy has been updated to reflect the new General Data Regulation Protection (GDPR) (EU) 2016/678 act implemented on 25 May, 2020.

 

Appointed Data Protection Officer / Data Controller: Instasoar DC

When we use the words “Instasoar,” “we,”, “our,” or “us” throughout this policy, we’re referring to Instasoar Ltd., which is understood as the company that manages your Instagram in the same way an agency does.  When we talk about “Services” in this policy, we are referring explicitly to the actions committed by Instasoar employees or Account Managers in order to help you grow your social media accounts.  By using the Services we provide, you agree to be bound by the Terms & Conditions outlined on our website.

 

Types of Data Collected

Types of Data that this Website collects includes: email address, cookies, usage data, first name, last name and country.  Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.  Some data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller.

Any use of Cookies – or of other tracking tools – by this Website or by the Data Controllers of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

 

Customer Data

Any content and information submitted by our registered users in order to help our account managers provide Services are collected and referred to in this policy as “Customer Data.” Instasoar Ltd does not misuse or expose Customer Data. Customer Data is stored in SSL secured, 2 factor authenticated locations and handled discreetly.  All Customer Data is handled safely And securely.

 

Website Visitor Data

Any content and information consented and submitted by our website visitors in order to help Instasoar tailor off-site experiences, of which may include advertisements (remarketing).  Instasoar Ltd does not misuse, or expose Website Visitor Data outside of the company. Certain Website Visitor Data may be used to improve the Company’s understanding of its target audience. Website Visitor Data is anonymized unless specified.

We use miscellaneous types of information when we provide Services to our Website Visitors. Uses include:

 

Data Processing

How Data Is Processed

Instasoar takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Instasoar, in some cases, the Data may be accessible to certain employees in charge and the Data Controller, who are involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of these parties may be requested from Instasoar at any time.

 

Legalities of Data Processing

Instasoar may process Personal Data relating to Users provided one of the following is applicable:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Data Controller may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller;
  • processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Data Controller
  • processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

Instasoar and its Data Protection Officer can and will gladly help clarify the specific legal basis that applies to said processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

 

Where Data is Processed

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.

 

Data Retention

Personal Data shall be processed and stored for as long as required by the legitimate purpose they have been collected for.

 

Information on Personal Data Processing

The Company collects Personal Data in and through the use of the following services:

 

Google Analytics

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Opt Out Here

 

 

Paypal

Personal Data collected: Name, Country, Billing Details, other Payment Data and various types of Data as specified in the privacy policy.

Place of processing: United States –  See their Privacy Policy

 

Stripe

Personal Data collected: Name, Country, Billing Details, other Payment Data and various types of Data as specified in the privacy policy.

Place of processing: United States –  See their Privacy Policy

 

Apple Pay

Personal Data collected: Name and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – See their Privacy Policy

 

Namecheap

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – See their Privacy Policy

 

Smartsupp

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – See their Privacy Policy

 

Age Information

Services we provide are unavailable to children under the age of 18. If a child under the age of 18 has provided us with their information without a consenting parent/guardian, please contact us immediately.

 

User Rights

Users may exercise rights regarding the processing of their Persoanl Data by the Data Controller and/or the Company. Depending on the protection standards of the region the User finds themselves in, the User might have the right to:

  • Withdraw Consent. Users may withdraw previously given consent to the processing of their Personal Data.
  • Object to Data Processing. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access Their Data. Users have the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and Seek Rectification:Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict Data Processing:Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
  • Remove or Delete Personal Data: Users have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller.
  • Transfer their Data: Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge Complaint: Users have the right to bring a claim before their competent data protection authority.
 

The Right to Object to Processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

Exercising Rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Data Controller as early as possible and always within one month.

 

Defining Broader Protection Standards Applicability

Most provisions of this document concern all Users. Some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • is performed by an Data Controller based within the EU;
  • concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • concerns the Personal Data of Users who are in the EU and allows the Data Controller to monitor such Users’ behavior taking place in the EU.
 

Additional Information on Data Collection & Data Processing

 

Legal Action

The User’s Personal Data may be used for legal purposes by the Data Controller in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

 

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

 

System Logs

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

 

Information not mentioned in this Privacy Policy

More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information at the beginning of this document.

 

“Do Not Track” Requests

This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

 

We may occasionally update this policy. If you continue using the Services we provide after changes are put into effect, you hereby agree to our latest policy revision as and when we update it here..

 

Contact Us

If you have any questions about this Privacy Policy, please do not hesitate to contact us addressing the Data Controller as specified above in the section “Appointed Data Protection Officer / Data Controller” or via privacy@instasoar.co.uk

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