Version 0.2. Active as of 25th May 2018
Owner and Data Controller
PingPong (PINGPONG UX LIMITED) of Belmont Place, Belmont Road, Maidenhead, United Kingdom, SL6 6TB
Contact email: firstname.lastname@example.org
About this Policy
When you sign up to PingPong, your profile information will be revealed to PingPong UX Limited and also other clients or moderators ("Moderators"), who may invite you to usability study interviews ("Interviews"). We won't disclose your full name, but these Moderators will be able to view some of your personal information when you consent to this.
If you have any questions about PingPong's approach to privacy, please email us at email@example.com.
Consent to collection and recording of Personal Data in Interviews
If you accept an Invitation to an Interview sent out a Moderator, you give your consent for PingPong to create an audio and video recording and text transcription of the Interview (a "Video"). This will be used to back up the Moderator's notes and will allow individuals within their company or business group to watch the Interview, either live or at a later date. This allows them to use your feedback to improve their products or services.
Further collection of Personal Data
Your Personal Data is collected to allow us to provide our Product, as well as for user database management, managing contacts and sending messages, analytics, managing our hosting and backend infrastructure, handling payments, registration and authentication and displaying content from external platforms.
- IP Address Data
- Why: Several of our suppliers (Heroku, CloudFlare, Netlify, TokBox, Amazon Web Services, Google Cloud, Postmark, Mailchimp and Stripe) automatically collect your IP address. This is a common practice for security, fraud prevention and performance purposes. In some situations we may also convert your IP address into a rough geolocation to help us improve and personalize PingPong (for example, to display time data in your local time).
- Retention: Your IP address is required in order to use PingPong. Each of the suppliers mentioned here retain your IP address for different lengths of time, depending on their own published privacy policies. If you delete your account, PingPong will not store your IP address in our own database, unless it is related to necessary Legal & Billing Data (see below).
- Usage Data: including your timezone, broad location (town or district), web browser, operating system and the device you use, referral sources, email engagement data, data on how you use PingPong (including last login date and frequency), account signup date.
- Why: This information allows us to personalise PingPong to your needs and to improve our Product. We do not collect precise, real-time information about the location of your device.
- Retention: This data will be deleted or anonymised when you cancel your account.
- Profile Data: including your name, age country of residence, education background, profession, marital status, phone number and other registration information.
- Why: This information allows us to effectively match Testers with Moderators to participate in Interviews. We require you to complete all these fields in order to sign up to PingPong. You may also optionally upload an avatar or enter your gender, but can remove this at any time.
- Retention: If you delete your account, your profile data will be removed too. Please keep in mind that data you share with a Moderator before or during an Interview may be stored for longer (see below).
- Login Data: email address and password.
- Why: This allows us to create a unique login account for you and for you to securely access PingPong.
- Retention: We'll store this data until you delete your account. Your password will always be encrypted and stored securely.
- Social Account Data: Facebook Profile, LinkedIn Profile.
- Why: If you choose to connect your Facebook or LinkedIn profile to your PingPong profile, you will grant us read only access to your profile and we will store your social account ID, along with a secure 'access key' that Facebook or LinkedIn provide us with. If you grant us access in the dialog shown, we may also access your primary email, name, profile picture, gender and age range, which we may use to enhance your Profile Data on PingPong. We use Social Account Data as a 'quality signal' to confirm that your PingPong account belongs to a real person and therefore your Social Account Data may affect the number of Interview Invitations you receive. We will never post content to your social profiles without your permission and we will never request or access your private messages on these accounts.
- Retention: You can choose to disconnect your social accounts at any time, which will prevent us from being able to access them. Social Account Data will also be deleted if you choose to delete your PingPong account.
- Calendar Integration Data: Microsoft Exchange or Google Calendar account.
- Why: As a Moderator, you may optionally choose to connect your calendar account with PingPong so that we can display your real-time availability to others and book Interviews into your calendar when you're available. We know your calendar data can be very sensitive and we access it only for this purpose. We will never share details of any specific events inside your calendar with other users, and we'll never store a copy of your calendar on our servers.
- Retention: You can remove this integration at any time, which will prevent us from accessing your calendar.
- Sales and Support Communications and Notification History (including email and message interaction metadata)
- Why: We use a number of services, including IM chat platforms and CRMs (such as Intercom and HubSpot) to communicate with our current and prospective users for sales and support purposes. If you delete your account, we may retain this information so that we can understand your case history and answer any concerns you have in the future. However, we won't use this information to send you unsolicited marketing communication.
- Retention: We typically store support and sales conversations for up to 2 years from the last date of communication. You may contact us to request manual deletion of this data sooner, if you choose. We may store a record of any SMS notifications for Interviews that we send to Testers for up to 3 months.
- Legal & Billing data (company name, country, billing address, billing details, VAT number, accounting email, transaction history and invoice history)
- Why: If you're a Moderator, we need to collect certain information in order to invoice you for PingPong. We use a third party payment processor (Stripe) for all invoice payments. We don't store any personally identifiable information or financial information such as credit card numbers ourselves. Instead, all such information is provided directly to Stripe when you buy credits on PingPong.
- Retention: Up to 7 years so that we can comply with legal and accounting requirements.
- Payout Data (PayPal email address, payout history, UK residential address)
- Why: To comply with accounting and legal rules, we also keep a record of payouts we make to Testers. As we're a UK company, we also store the residential address of any UK Testers in case this is legally required from us in the future.
- Retention: Up to 7 years.
- Interview Data (Screener responses, interview video, interview audio, interview instant messaging, Social Account Data, user ratings).
- Why: Testers will receive Invitations to participate in Interviews with our Moderators. These Invitations may also include a set of Screener questions requesting additional information. To participate in an interview, the Tester must consent to sharing their Profile Data and email address with the Moderator. The Tester must enable video, audio and screen sharing. PingPong will make a recording of the Interview.
- Retention: If you do choose to accept an Interview Invitation or complete a Screener, the Moderator will have access to the corresponding Interview Data for 2 years.
Special category data
PingPong doesn't require any "special category data" (as defined by Article 9(2) of the GDPR) as a prerequisite for using our Product. Some Interviews or Screeners may ask you if you are willing to provide such information. By doing so, you consent to the special category data becoming part of the Interview Data and being disclosed to the Moderator. You're free to decline these Invitations if you prefer not to disclose this type of data.
PingPong has been built to connect Moderators with the best matched Testers for their Interviews. Better matches means happier Moderators and more payouts for Testers. We analyse the data you provide us, along with your Usage Data, to automatically profile your account and match you to appropriate Interviews.
How we contact you
We may use the information you provide us to contact your from time to time to provide you with important information, required notices and marketing promotions.
You can unsubscribe from this messaging by following the 'unsubscribe' option in the message.
How we process and use your Data
Methods of processing
We care about keeping your information confidential. We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Personal Data. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Processing of your Data is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
We use others to help us provide our services (for example, maintenance, analysis, audit, payments, fraud detection, marketing and development). These organisations and individuals will have access to your information as is reasonably necessary to perform their individual tasks on our behalf, and are obligated not to disclose or use it for other purposes.
Legal basis of processing
We may process your Personal Data if one of the following applies:
- You have given your consent for one or more specific purposes. Note: Under some legislations we may be allowed to process Personal Data until you object 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 you and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which we are subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- Processing is necessary for the purposes of the legitimate interests pursued us or by a third party.
- PingPong is involved in a merger, acquisition, or sale of all or a portion of its assets. In such a situation you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
In any case, we will gladly help to clarify the specific legal basis that applies to the 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.
The Data is processed in a variety of geographical locations.
Depending on your location, data transfers may involve transferring the your Data to a country other than your own. To find out more about the place of processing of such transferred Data, see the list below.
You 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 PingPong to safeguard your Data. If any such transfer takes place, you can find out more below or inquire with us using the email address provided above.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Personal Data collected for purposes related to the performance of a contract between us and you shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by us within the relevant sections of this page or by contacting us.
We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Transfer of data outside the EU
We transfer specific User Provided and Automatically Collected data outside of the European Union/European Economic Area for the purposes of improving and optimising our Product, communicating with you and marketing the Product more effectively.
By using the Product, you consent that such data may be processed in a country outside the European Union. At present, some Data is transferred to the following online service companies and third party processors outside the EU and subject to the privacy policies listed here:
Specific individuals or organisations contracted by PingPong to work on our product may also have access to your data. A list of these is available on request.
You can stop all ongoing collection of information by the Product easily by deleting your account via your account settings page. Please note that if you have participated in Interviews, we may not be able to erase all your data immediately.
You may exercise certain rights regarding your Data processed by PingPong:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
- Object to processing of your Data. You have the right to object to the processing of your Personal Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access your Data. You have the right to learn if your Personal Data is being processed by PingPong, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your Personal Data and ask for it to be updated or corrected.
- Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Personal Data. In this case, PingPong will not process your Personal Data for any purpose other than storing it.
- Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Personal Data from PingPong.
- Receive your Personal Data and have it transferred to another controller. You have the right to receive your Personal 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 Personal Data is processed by automated means and that the processing is based on your consent, on a contract which you is part of or on pre-contractual obligations thereof.
- Lodge a complaint. You have a right to complain to the ICO if you think there is a problem with the way we are handling your Personal Data.
Details about your right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in PingPong or for the purposes of the legitimate interests pursued by the PingPong, you may object to such processing by providing a ground related to their particular situation to justify the objection.
You must know that, however, should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.
How to exercise these rights
Any requests to exercise your rights can be directed to PingPong through the contact details provided above. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Children under the age of 18 are strictly prohibited from using PingPong. If you suspect or become aware that a child has used PingPong, please contact us immediately so that we can delete their account and information.
Additional information about Data collection and processing
Your Personal Data may be used for legal purposes by the PingPong in Court or in the stages leading to possible legal action arising from improper use of PingPong or the related Services. You declare yourself to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, PingPong and any third-party services may collect files that record interaction with PingPong (System logs) use other Personal Data (such as the IP Address) for this purpose.
How "Do Not Track" requests are handled
PingPong does not support "Do Not Track" requests on our main product. You can however opt out of Google Analytics cookies on our marketing website by enabling Do Not Track. To determine whether any other third-party services we use honour "Do Not Track" requests, please read their privacy policies.
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
"PingPong" is a service owned and operated by PingPong UX Limited, a registered company in the UK whose company number is 10551060. All references to "PingPong", "we", "us" etc refer to PingPong UX Limited. PingPong is the means by which your Personal Data is collected and processed.
A "Tester" is a user who has registered a tester account on PingPong whereby they are invited to Interviews and will be compensated for their participation in these.
Screener (or Screener Questions)
One or more questions which are attached to an Interview Invitation. The Tester will be required to complete these questions in order to respond to the Invitation and be considered for an Interview.