Legal agreements

Privacy Policy

Last revised: 30.10.2018

Summary

1. This policy defines and clarifies what data is collected in connection with CEED LTD (doing business as ‘pi-top’) products and services.

2. This document also explains the manner in which pi-top makes use of the data it collects, where the data is stored, and how such data is secured and protected.

3. Briefly:

In order to enable you to use pi-top products and services, the company needs to process some of your data. If the company develops the need to process your data for any other purpose apart from offering you pi-top products and services, the company will always seek to obtain your express consent in advance.
Some partners, such as Google, assist the company in developing pi-top products and services, and the company may share limited data with them - but only for pi-top's own purposes.
The company will absolutely not share your data for third party advertising purposes.

4. Finally, this document outlines your rights in relation to managing your personal data.

Greetings! This Privacy Policy offers you all the details you need relating to how your personal data is being collected, stored and used. You will know exactly what happens to your data when you are using pi-top products or services. To this end, the company has put together two versions, the first being a full-text version which is legally binding, and the second being a simplified version which is simply provided as a courtesy and for your convenience. The second version consists of section summaries which are designed to make the legal language easier to digest. You will be required to agree to this Privacy Policy before you use a pi-top product or service for the first time. If you have any questions you can contact us at marketing@pi-top.com.

Full text

Brief summary

1. Who we are

1.1. We are CEED LTD, a company incorporated in England, and a data controller, as defined by European Union data protection legislation. Hereafter, we will be calling ourselves ‘pi-top’ as pi-top is the name under which CEED LTD products and services are marketed. You may contact us via email at marketing@pi-top.com or by mail: Unit 323, Metal Box Factory, 30 Great Guildford Street, SE1 0HS, UK.

Hi, we are pi-top and we are based in the UK. You can find our contact details opposite.

1.2. In order to protect all your personal data better and more efficiently, we designated a Data Protection Officer (or DPO) who is responsible for the supervision and implementation of our data protection strategy. The DPO also ensures compliance with all the necessary legal requirements. You can contact our DPO at the following email address: marketing@pi- top.com.

Should you have any questions or doubts concerning personal data protection, do not hesitate to contact our Data Protection Officer (contact details opposite).

2. What this privacy policy governs

2.1. This Privacy Policy applies to: our website, online portals (i.e., pi-topCLASSROOM), forums, social media channels, games, technical and customer support and any other services we provide to you (Hereafter, we will be using the term ‘pi-top services’ to refer to any and all items enumerated under the list above).

2.2. In more detail, this Privacy Policy governs personal data (or, as it is called in the United States, ‘personally identifiable information’) and non-personal data (or, as it is called in the United States, ‘non-personally identifiable information’), which we collect from you when you’re using pi-top services. (‘Personal data’ essentially designates data, which, on its own or in combination with other data, can be used to directly or indirectly identify you personally).

2.3. We respect your right to privacy. Therefore, we will only process your personal data in accordance with applicable legislation in the European Union and other countries where we offer our products and services.

This Privacy Policy explains the different types of data we collect from you when you are using pi-top products and services. We operate in full compliance with privacy laws.

3. Additional protection for young children

3.1. In recognition of our special obligation to protect personal data obtained from children, we do not and will not knowingly collect personal data from any child under 13 without consent from their parent or guardian. If you are a parent or guardian and are concerned about the transfer of personal data regarding your child, please contact us directly at support@pi-top.com.

If you are under 13 and would like to use our services, explicit consent on your behalf from your parent or guardian will be required.

4. Information we collect

4.1. When you use pi-top services, we may collect the following data if relevant:

Your name and surname;

Your email address;

Any username (such as a pi-top or Freshdesk username);

IP address;

Details of your online platform account, such as a pi-top account, but not any financial details; Details of your use of pi-top services including, but not limited to: metrics data regarding the time at and manner in which you use pi-top services, your geographical location data, and traffic data;

Any additional meta-data we may receive (when completing your request, e.g. an API call) any device which you use to access our services, including: internet and/or network connection, any mobile device identifier, your operating system, browser type or other software, or your hardware or other technical details. This is technical data about pi-top users and their actions and patterns which does not provide personal data;

Details about your use of social networks as related to your interaction with pi-top services but only if you have linked pi-top services to a social networking account. This refers to data from Facebook and other social networks, including access to your friend list as well as aggregated non-personal analytics data about our users. Any data collection described under this section will strictly in accordance with Facebook's and other networks' terms and conditions – to the extent necessary to provide you with all functions of pi-top products and services; and

Any other data which you supply when using pi- top services.

If and when you use our forums, we may additionally process data generated automatically related to your activity in the forums: date of last activity, subscribed threads, favourite posts, private messages, and forum posts.

We may also collect additional data via forums such as: website addresses, biography, contact data, location, interests, profession, and user preferred language.

If you contact pi-top technical support, we may process other data required to help you with any queries or support matters. Any such as data is collected in crash logs that are gathered by your pi-top device.

When you use pi-top services, we collect some basic data about you and your activity.

We and our partners also collect data about you through our use of cookies. You can find out more details concerning this in our Cookie Policy. The Cookie Policy is an integral part of this Privacy Policy.

If you contact technical support we may ask you to provide us with some additional data, such as your crash logs.

For the purposes of contests or competitions organised by pi-top, we may process additionally your correspondence address, phone number, image of yourself, bank account number, or social networks identifiers.

When you participate in any contests or competitions organised by pi-top, we may require you to provide us with additional details about yourself.

In order to use our products and services, we need to process data described above. If you do not agree to provide us with the above- mentioned data, you will not be able to use our products and services or enter any contest or competition organised by pi-top.

The data described above is necessary for us to provide you with pi-top services.

5. How your personal data is collected

5.1. We may collect and process data about you that comes under our control in the following manners:

data given when you contact us or report a problem with pi-top services;
data you give us via pi-top services or that we receive in connection with your activity on the pi-topDASHBOARD and online portals such as pi-topCLASSROOM;
data regarding your activity as a user of our services (in addition to your IP address, country of origin, purchases, browsing habits, software usage patterns, software versions);
data regarding pi-top services collected via surveys or polls that you choose to answer voluntarily.

We collect and process data that you give us in connection with our products and services or that we receive in connection with your activity on the pi-top systems.

5.2. As far as your payment details are concerned, we will not receive or store any of your payment details. Any payment details are handled entirely by the relevant payment platform and/or payment method/processor. When you buy any pi-top product, we are notified by the payment processor once the transaction takes place and use this notification to ensure you receive your purchased items. We therefore do not receive any of your actual payment information, such as your card number, security code, or billing address. We only store data regarding transaction dates, value, currencies, and the products underlying the transaction.

We do not collect any of your payment details. We only receive data that a purchase took place. The only data we store is related to transaction dates, currencies, value and the products that you ordered.

6. The purpose for which we use your data (legal basis for data processing)

6.1. When we process personal data about you, we do so only as necessary to provide you with the pi-top services you desire (i.e. to perform the agreement between us), to meet our legal obligations or to fulfil the so-called ‘legitimate interests’ of pi-top, or in accordance with the other cases described in the section ‘How is your data used?’.

As further clarification, legitimate interests comprise any lawful purposes that could be reasonably expected to be necessary to the proper conduct of pi-top business, such as: protecting the security of the data we process, marketing pi-top products and services, ensuring our marketing is relevant to you, and conducting anti-fraud checks. When we rely on the legitimate interest as a legal basis for processing your data, we consider and balance any potential impact on you and your rights. For other purposes, we will ask for your consent. You will be entitled to withdraw this consent at any time with no impact on the validity of the processing before your consent has been withdrawn.

6.2. When we transfer your data outside the European Economic Area, we do so on the basis of a variety of legal mechanisms. This is described in more detail under the ‘Trusted Partners’ section.

In order for you use our services we need to process some of your data. If we need to process your data for any other purpose, we will always ask you for your explicit consent in advance. You always have the right to withdraw your consent at any time.

7. How we handle your personal data

7.1. The data collected by pi-top from you is stored on our secure servers in England or – only if necessary - by those of our Trusted Partners as described below. We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction or damage. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

We will store your data on our secure servers in Europe or on those of our Trusted Partners. We will do our utmost to keep your data safe.

7.2. We will retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. In certain special cases, a longer retention period might be required by law, such as for tax reasons, accounting purposes or other legal requirements and obligations. When we no longer require your personal data in order to provide our services to you, we will either delete it or anonymise it.

we will store the data that is associated with the services you use for the duration of the agreement in order to enable you to access pi-top services (e.g., project progress on pi-topDASHBOARD or pi-topCLASSROOM). Should you close or delete your pi-top account, the limited data that we collected about you will still be retained for an additional few years for tax, legal and accounting purposes;
in the event of you contacting us without using any pi-top service, we will retain correspondence with you for as long as it is reasonably necessary to deliver meaningful and efficient assistance to you. Following this, we will only be storing such correspondence for the shortest period necessary in the discharging of pi-top’s legal and accountability obligations;
for marketing purposes, we will store data as long as we have your ongoing valid consent. If you choose to unsubscribe, we promise to delete or anonymise all your relevant personal data, without undue delay and no later than within 30 days from the moment we receive a request to unsubscribe.

In the vast majority of cases, we will store your data until you finish using our services. After that we may still use limited data about you for tax, legal or accounting reasons.

8. How is your data used?

8.1. Your data may be used for the following purposes:

To carry out our obligations arising from any agreements between you and us;
To communicate with the users of our services;
To provide you with products or services that you request from us;
To provide you with marketing information (including personalised and targeted marketing emails), which we consider may be of interest to you. For example, we may send you newsletters or emails about pi-top products and services (this is entirely optional and we will ask you for informed permission first);
To allow you to participate in interactive features of pi-top services should you choose to do so;
To notify you about modifications to pi-top services;
To maintain, improve or modify pi-top products or services;
To organise contests and competitions (including contact with participants, evaluation of applications, distribution of prizes, and payment of tax on prizes);
To calculate conversion rates and other performance elements of pi-top products and/or services;
For legal, tax, and accounting purposes;
For accountability purposes as defined by EU legislation (GDPR);
To target and personalise our marketing communications, offers and advertisements that we display on our websites and services as well as those of third parties based on the combined data we have collected about you.
We will use your data to carry out pi-top services and improve them. We will also use your data to communicate with you, for example through newsletters or emails.

In the vast majority of cases, we will store your data until you finish using our services. After that we may still use limited data about you for tax, legal or accounting reasons.

8.2. Whenever we personalise or target our marketing communications, offers and advertisements, we may profile your personal data. This means that we may use the data we collect to adjust the communication addressed to you in order to meet your needs and expectations regarding the performance of pi- top products and services. In such cases, we do not, however, use your personal data for profiling, which would constitute automated decision-making that could affect your legal situation. In simpler terms, we do not use algorithms to make decisions which would have an impact on your individual legal rights or affect your legal status or rights under the agreement between us. For example, we do not make automatic offers based on your behaviour on online portals such as Further.

If you decide that you no longer want to receive personalised offers, product recommendations from us, or any advertising news at all, you can opt out of this service at any time.

We gather data about when and how you use pi-top services in order to offer you the best service possible. However, we will never make automatic decisions based on profiling that could affect your legal situation (e.g. automatic offers or discounts based on your behaviour in the game).

8.3. We might process some aggregated and general non-personal data related to user behaviour (e.g. sales per region) with third- party partners who work with us to provide pi- top products and services to you, for example, payment providers. We are doing this in order to support, improve or amend pi-top products and services. We may also share non-personal data with data analysis services to help us better run pi-top services.

Occasionally and only as described immediately opposite, we may have to share anonymised, non-personal data in order to better run our services. In such situations, everything regarding your data is anonymised, making it impossible for you to be identified.

9. Data sharing

9.1. Please remember that any communications you have via pi-top services (e.g. via private messages or pi-top forums or via social media) may reveal details about you. Also, any data you post publicly using pi-top products and services will be publicly available to pi-top users and others. We are not responsible for your use of any private personal data which you choose to make available via pi-top services, or the activities of other users or other third parties to whom you give or make available your data.

When you use pi-top products and services you have the option to share your own personal data with others or publicly. However, please be aware that you are responsible for this type of data sharing.

10. Third party data collection

10.1. pi-top services may, from time to time, contain links to and from the websites or services of third parties. Our Privacy Policy does not cover these external sites or companies. For a complete picture of your data rights vis-à-vis these third parties, please refer directly to their privacy policies.

You may find third party links in pi-top services, or we might direct you to third parties. They may collect data from you in accordance with their own privacy policies. Please take the time to take a look at them.

10.2. Some services may involve interacting with our subsidiaries or potentially with other pi-top trusted partners, for example, Freshdesk. In order to do this, we may need to share some of your personal data with our Trusted Partners.

We provide some services via trusted partners like Freshdesk – we will share some data with them.

11. Trusted partners

11.1. We may share your data with the following Trusted Partners, who were engaged by us to help deliver our services and functionalities to you. Please rest assured that we always provide our partners with the minimum data necessary for them to achieve the purpose of their cooperation with us. They have access to limited data about you and process such data on our behalf only for the purposes set out below:

CEED INC – our subsidiary that helps us market in the United States;
Our partners who provide us with internal management and data-sharing tools;
Our partners who help us in data analysis by providing us with analytical tools;
Our partners who help us manage our newsletters and email communications by providing us with email marketing tools;
Our professional advisors who assist with legal, tax, audit or accounting matters;
Social media platforms for the purpose of personalised and targeted marketing.

11.2. When required by law, we may also share your data with the police or other government authorities (including your IP address and details of suspected unlawful or fraudulent activity such as unauthorised use of payment methods).

We sometimes share data with our Trusted Partners. They usually take care of stuff like data analytics, internal management tools or support us in marketing activities.

11.3. Your data may be processed, stored and transferred to countries outside your country of residence and beyond the European Economic Area (EEA), such as Switzerland or the United States. Privacy laws in these countries may not offer the same level of protection as in your country or in the EEA. But whenever we share your personal data outside the EEA, we will do so on the basis of EU standard contractual clauses which establish adequate protection of your personal data.

Whenever we share your personal data outside Europe, we make sure that the data is duly protected.

12. Push notifications

12.1. With your prior approval, as a user of our products and services, you may be sent push or local notifications to your mobile device to give you updates regarding pi-top products and services. You can manage this, normally from your device’s Settings section.

We are entitled to use mobile push notifications if you approve it.

13. Miscellaneous

13.1. We may be required to release personal data to comply with law enforcement and other legal requirements.

We may be required to comply with law enforcement requests to surrender personal data.

13.2. In the event of a reorganisation or merger of pi-top we may transfer personal data to an involved third party who will protect to at least the same level as we do in this privacy policy.

In the event of any change in pi-top’s corporate structure or ownership, your personal data will still be protected to at least the same degree as it is right now.

14. Your rights

14.1. You have the right to object to the processing of your personal data in certain situations and for marketing purposes at any time. You can do so by contacting us on the email address: marketing@pi-top.com.

14.2. You have the following additional rights:

You have the right to access data held about you;
You may contact us to request that we delete your personal data from our system;
You may ask us to rectify/correct your personal data, if appropriate;
You may ask us to restrict the processing of your data;
You have the right to transfer your data to another entity;
You have the right to file a complaint with a data protection authority;
You can exercise these rights by contacting us at marketing@pi-top.com.

14.3. In case of any concerns or questions about your privacy, please do contact us and we will do our best to assist you. You can reach us at: marketing@pi-top.com or contact our Data Protection Officer at dpo@pi-top.com. If, however, you feel we have not satisfactorily dealt with your concern, you can report it to your local data protection authority or the UK regulator - the Information Commissioner's Office (ICO).

14.4. Under California law, California residents who have an established business relationship with us may choose to opt out of disclosure of personal information data about them to third parties for direct marketing purposes.

14.5. If you would like to exercise any of these rights or have any queries regarding them, please contact: marketing@pi-top.com

You have several rights regarding your personal data, including the right to request information concerning how your personal data is used, the right to access your data, the right to make amendments to your personal data, the right to have us delete all your data, the right to to restrict the processing of your data or to have your data transferred to another entity. If you are unsure of how your rights are affected in connection with your use of pi-top products or services, you can always send an email to marketing@pi-top.com or dpo@pi-top.com and we will do our best to support you.

15. Changes to this privacy policy

15.1. We may change this Privacy Policy if we deem it necessary or useful. Envisaged reasons for which we might choose to amend our Privacy Policy are legal reasons or changes in the services we provide. If we change our Privacy Policy, we will make the altered Privacy Policy available online and update the "Last Updated" date accordingly.

15.2. The updated Privacy Policy will become legally binding 30 days after being posted online. During this period, do not hesitate to contact us if you have specific questions about any of the changes.

We can bring changes to this Privacy Policy, but if we do this, we will publish the updated version online.

15.3. Unfortunately, if you do not agree to the changes we make to our Privacy Policy, we must ask you to cease using pi-top products and services. This is because we are obliged by law to guarantee a minimum of legal rights and protections to you as a pi-top customer whilst running our services consistently across our entire user base. We therefore encourage you to get in contact if you have queries.

Please feel free to contact us if you have any questions regarding the changes.

16. Terms of service

16.1. We would also like to remind you that our Terms of Service contain more information about the services pi-top offers. Certain sections of our Terms of Service apply to this Privacy Policy. You can find pi-top’s Terms of Service here.