PRIVACY NOTICE
Last updated August 13, 2020
Thank you for
choosing to be part of our community at Orcestra, Inc. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at hello@orcestra.net.
When you visit our website https://orcestra.net (the “Website“), use our mobile application, as the case may be (the “App“) and more generally, use any of our
services (the “Services“, which include the Website and App), we appreciate that you are trusting us with your personal information. We take
your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this
privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related
services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL
LOGINS?
7. IS YOUR INFORMATION
TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY
RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS
NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
1. WHAT INFORMATION
DO WE COLLECT?
Information collected through our App
In Short: We
collect information regarding your mobile device, push
notifications, when you use our App.
If you use our App,
we also collect the following information:
§ Mobile Device Access. We may request access or permission to
certain features from your mobile device, including your mobile
device’s sms messages, reminders, and other features. If you
wish to change our access or permissions, you may do so in your device’s settings.
§ Mobile Device Data. We automatically collect device
information (such as your mobile device ID, model and manufacturer), operating
system, version information and system configuration information, device and
application identification numbers, browser type and version, hardware model
Internet service provider and/or mobile carrier, and Internet Protocol (IP)
address (or proxy server). If you are using our App, we may also collect
information about the phone network associated with your mobile device, your
mobile device’s operating system or platform, the type of mobile device you
use, your mobile device’s unique device ID and information about the features
of our App you accessed.
§ Push Notifications. We may request to send you push
notifications regarding your account or certain features of the App. If you
wish to opt-out from receiving these types of communications, you may turn them
off in your device’s settings.
The information is
primarily needed to maintain the security and operation of our App, for
troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE
YOUR INFORMATION?
In Short: We process your information for
purposes based on legitimate business interests, the fulfillment of our
contract with you, compliance with our legal obligations, and/or your consent.
We use personal
information collected via our Services for a variety of business
purposes described below. We process your personal information for these
purposes in reliance on our legitimate business interests, in order to enter
into or perform a contract with you, with your consent, and/or for compliance
with our legal obligations. We indicate the specific processing grounds we rely
on next to each purpose listed below.
We use the
information we collect or receive:
§ To send you marketing and promotional
communications. We and/or our
third-party marketing partners may use the personal information you send to us
for our marketing purposes, if this is in accordance with your marketing
preferences. For example, when expressing an interest in obtaining information
about us or our Services, subscribing to marketing or otherwise contacting
us, we will collect personal information from you. You can opt-out of our
marketing emails at any time (see the “WHAT ARE YOUR
PRIVACY RIGHTS” below).
§ Deliver targeted advertising to
you. We may use your
information to develop and display personalized content and advertising (and
work with third parties who do so) tailored to your interests and/or location
and to measure its effectiveness.
3. WILL YOUR
INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your
consent, to comply with laws, to provide you with services, to protect your
rights, or to fulfill business obligations.
We may process or
share your data that we hold based on the following legal basis:
§ Consent: We may process your data if you
have given us specific consent to use your personal information in a specific
purpose.
§ Legitimate Interests: We may process your data when it
is reasonably necessary to achieve our legitimate business interests.
§ Performance of a Contract: Where we have entered into a contract
with you, we may process your personal information to fulfill the terms of our
contract.
§ Legal Obligations: We may disclose your information
where we are legally required to do so in order to comply with applicable law,
governmental requests, a judicial proceeding, court order, or legal process,
such as in response to a court order or a subpoena (including in response to
public authorities to meet national security or law enforcement requirements).
§ Vital Interests: We may disclose your information
where we believe it is necessary to investigate, prevent, or take action
regarding potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal activities,
or as evidence in litigation in which we are involved.
More specifically,
we may need to process your data or share your personal information in the
following situations:
§ Business Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger, sale of
company assets, financing, or acquisition of all or a portion of our business
to another company.
4. DO WE USE
COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking
technologies to collect and store your information.
We may use cookies
and similar tracking technologies (like web beacons and pixels) to access or
store information. Specific information about how we use such technologies and
how you can refuse certain cookies is set out in our Cookie Notice.
5. DO WE USE GOOGLE
MAPS?
In Short: Yes, we use Google Maps for the purpose
of providing better service.
This Website or App uses
Google Maps APIs which is subject to Google’s Terms of Service. You may find
the Google Maps APIs Terms of Service here. To find out
more about Google’s Privacy Policy, please refer to this link.
6. HOW DO WE HANDLE
YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to
our services using a social media account, we may have access to certain
information about you.
Our Services offers
you the ability to register and login using your third-party social media
account details (like your Facebook or Twitter logins). Where you choose to do
this, we will receive certain profile information about you from your social
media provider. The profile Information we receive may vary depending on the
social media provider concerned, but will often include your name, email
address, friends list, profile picture as well as other information you choose
to make public on such social media platform.
We will use the
information we receive only for the purposes that are described in this privacy
notice or that are otherwise made clear to you on the
relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your third-party
social media provider. We recommend that you review their privacy notice to
understand how they collect, use and share your personal information, and how
you can set your privacy preferences on their sites and apps.
7. IS YOUR
INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process
your information in countries other than your own.
Our servers are
located in. If you are accessing our Services from outside, please be
aware that your information may be transferred to, stored, and processed by us
in our facilities and by those third parties with whom we may share your
personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?“
above), in and other countries.
If you are a
resident in the European Economic Area, then these countries may not
necessarily have data protection laws or other similar laws as comprehensive as
those in your country. We will however take all necessary measures to protect
your personal information in accordance with this privacy notice and
applicable law.
8. HOW LONG DO WE
KEEP YOUR INFORMATION?
In Short: We keep your information for as long as
necessary to fulfill the purposes outlined in this privacy notice unless
otherwise required by law.
We will only keep
your personal information for as long as it is necessary for the purposes set
out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements). No purpose
in this notice will require us keeping your personal information for longer
than 1 year.
When we have no
ongoing legitimate business need to process your personal information, we will
either delete or anonymize such information, or, if this is not possible (for
example, because your personal information has been stored in backup archives),
then we will securely store your personal information and isolate it from any
further processing until deletion is possible.
9. HOW DO WE KEEP
YOUR INFORMATION SAFE?
In Short: We aim to protect your personal
information through a system of organizational and technical security measures.
We have implemented
appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission
over the Internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will
do our best to protect your personal information, transmission of personal information
to and from our Services is at your own risk. You should only access
the Services within a secure environment.
10. DO WE COLLECT
INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from
or market to children under 18 years of age.
We do not knowingly
solicit data from or market to children under 18 years of age. By using
the Services, you represent that you are at least 18 or that you are the
parent or guardian of such a minor and consent to such minor dependent’s use of
the Services. If we learn that personal information from users less than
18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18,
please contact us at privacy@orcestra.net.
11. WHAT ARE YOUR
PRIVACY RIGHTS?
In Short: You may review, change, or terminate
your account at any time.
If you are resident
in the European Economic Area and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details
here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are resident
in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Cookies and similar
technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your browser
to remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of
our Services. To opt-out of interest-based advertising by advertisers on
our Services visit http://www.aboutads.info/choices/.
12. CONTROLS FOR
DO-NOT-TRACK FEATURES
Most web browsers
and some mobile operating systems and mobile applications include a
Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and
collected. At this stage, no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about
that practice in a revised version of this privacy notice.
13. DO CALIFORNIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of
California, you are granted specific rights regarding access to your personal
information.
California Civil
Code Section 1798.83, also known as the “Shine The Light” law, permits our
users who are California residents to request and obtain from us, once a year
and free of charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes and the names
and addresses of all third parties with which we shared personal information in
the immediately preceding calendar year. If you are a California resident and
would like to make such a request, please submit your request in writing to us
using the contact information provided below.
If you are under 18
years of age, reside in California, and have a registered account with a
Service, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please
contact us using the contact information provided below, and include the email
address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on
the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g. backups, etc.).
14. DO WE MAKE
UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as
necessary to stay compliant with relevant laws.
We may update this
privacy notice from time to time. The updated version will be indicated by
an updated “Revised” date and the updated version will be effective as soon as
it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy
notice frequently to be informed of how we are protecting your
information.
15. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
If you have
questions or comments about this notice, you may email us at privacy@orcestra.net or
by post to:
Orcestra, Inc.
Unit 203 LRI Design
Plaza
210 N. Garcia
Street
Makati, Metro
Manila 1206
Philippines
HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the
applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or
delete it in some circumstances. To request to review, update, or delete your
personal information, please submit a request form by clicking here. We will respond to your request
within 30 days.