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1. WHO WE ARE AND OUR APPROACH TO PRIVACY

1.1 Giraffe360 Limited ("Giraffe360", "we", "our", or "us") is committed to protecting and respecting your privacy.

1.2 We provide a service to real estate companies (our "Partners") that allows them to take high-dynamic-range images of properties, using Giraffe360 camera equipment, in order to create virtual tours, floorplans and other high quality photography, and make these available through their websites, apps and social media pages. We do this by automatically sending the images taken by the Giraffe360 cameras to our cloud-based production service that creates the 3D representations and other content of the captured properties for use and distribution by the Partner (the "Giraffe360 Service").

1.3 This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access and use our website at giraffe360.com, including any subdomains of our website (the"Giraffe360 Website"), subscribe to the Giraffe360 Service, or when a Partner uses the Giraffe360 Service to take images of your property.

1.4 If you have any questions about this Privacy Policy or how we use your personal information, please contact us using the details at the end of this Privacy Policy.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

2.1 Giraffe360 determines and is responsible for the uses of your personal information described in this Privacy Policy, meaning that we will be the controller of your personal information when we use it in these instances, including when you access the Giraffe360 Website.

2.2 We may also receive some personal information about you, such as pictures or layout of your property, when we provide the Giraffe360 Service to our Partners. We only do this on the instructions of our Partners, so the Partner collecting this information when using the Giraffe360 Service determines and is responsible for how we use such personal information, meaning that they will be the controller of your personal information in those instances.

3. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

Personal information you submit to us

3.1 We collect personal information that you submit directly to us, including information you provide when you fill in an enquiry form on the Giraffe360 Website, interact with us using our chatbot function, or communicate with us about our products and services.

3.2 We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information marked as mandatory, we may not be able to respond to your queries or provide other services to you.

3.3 The list below sets out the categories of personal information we collect about you, how we use that information and the lawful basis we rely on to process that personal information:

Contact information, such as your name, phone number, email address, the name of your organisation and the country that you live in. We use this information to communicate with you about our products and services and to respond to any queries, issues or concerns you have. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

Comments and opinions. When you contact us directly, we will record your comments and opinions. We will use your comments and opinions to address your queries, issues and concerns and improve our products and services. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely communicating with prospective customers and others about our products and services.

Personal information collected from our Partners through the Giraffe360 Service

3.4 When a Partner captures imagery using our Giraffe360 camera equipment we may collect personal information which is depicted within that imagery. We collect and use this personal information on the instructions of the relevant Partner in order to provide the Partner with the Giraffe360 Service.

3.5 We also use this information for our own internal purposes to improve the accuracy and quality of our camera equipment and our processing algorithms, and for marketing purposes. The lawful basis for processing this personal information is that processing is necessary for our legitimate interests, namely, to develop and improve our products and the Giraffe360 Service and to inform our marketing strategy.

3.6 We do not use this information for any other purposes, but this information may be publicly displayed if the Partner chooses to display the imagery created through the Giraffe360 Service publicly through their website, app or social media (the "Partner Service"). You should ensure that you read the privacy notice or policy applicable to any Partner Service you use to understand how your personal information may be used by the relevant Partner when they use the Giraffe360 Service.

Personal information we collect automatically

3.7 We also automatically collect personal information indirectly about how you access and use the Giraffe360 Website and information about the device you use to access theGiraffe360 Website:

Information about how you access and use the Giraffe360 Website. For example, the website from which you came and the website to which you are going when you leave the Giraffe360 Website, how frequently you access the Giraffe360 Website, the time you access the Giraffe360 Website and how long you use it for, the approximate location that you access the Giraffe360 Website from, and other actions you take on the Giraffe360 Website.

Information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to access the Giraffe360 Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Giraffe360Website through the device, your internet service provider or mobile network and your IP address.

3.8 We use the information we collect automatically to present the Giraffe360 Website to you on your device and to determine products and services that may be of interest to you for marketing purposes. We also use the personal information we collect from you to monitor and improve the Giraffe360 Website and business, and to help us to develop new features on the Giraffe360 Website.

3.9 The processing of the personal information we collect from you automatically is necessary for our legitimate interests, namely: to tailor the Giraffe360 Website to the user and to improve the Giraffe360 Website generally; to monitor and resolve issues; for marketing purposes; and for the detection and prevention of fraud.

3.10 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Giraffe360 Website and developing new products and features. We may also share such anonymised information with others.

4. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

4.1 We will store the personal information we collect for our own purposes for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.

4.2 Our Partners may, however, ask us to store your personal information relating to the images captured through the Giraffe360 Service on their behalf for longer. Please refer to the privacy notice for the Partner Service you use to find out how long the relevant Partner may store your personal information.

5. RECIPIENTS

5.1As required in accordance with how we use your personal information, we may share your personal information with the following:

1. (a) Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, customer relationship management, legal, or analytic services.
2. (b) Purchasers and third parties in connection with a business transaction. Your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
3. (c) Law enforcement, regulators and other parties for legal reasons. We may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Giraffe360, its users or others.

6. MARKETING AND ADVERTISING

6.1 From time to time we may contact you with information about our services, including sending you marketing messages and asking for your feedback on our services.

6.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

6.3 We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

7. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

7.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers.

7.2 International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information may be processed outside of the EEA; these international transfers of your personal information will be made pursuant to appropriate safeguards, including:

1. (a) ensuring that recipients or the country in which they are located are deemed by the European Commission to provide adequate protection for personal information; and
2. (b) ensuring that transfers are subject to standard contractual clauses approved by the European Commission for the transfer of personal information.

7.3 We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.

7.4 If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy policy.

8. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

8.1In accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv)a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

8.2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

8.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

8.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

9. LINKS TO THIRD PARTY SITES

The Giraffe360 Website may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

10. OUR POLICY TOWARDS CHILDREN

The Giraffe360 Website is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

11. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

12. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

13. CONTACTING US

13.1 Please contact support@giraffe360.com if you have any questions, comments and requests regarding this privacy policy.

13.2 This privacy policy was last modified on 24 August 2020.

Last Updated: 24 August 2020 

1. COOKIES AND SIMILAR TECHNOLOGIES USED ON OUR WEBSITE

1.1 Giraffe360 Limited ("we", "our", or "us") is committed to protecting your privacy. This Cookie Notice describes our use of cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") on our website, located at giraffe360.com and any subdomains of that website (our "Website"). For more information about the personal information we collect and process when you visit our Website or use our products or services please see our Privacy Policy

1.2 Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to monitor and analyse how you use and interact with our Website so that we can continue to improve our Website. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.

1.3 Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes. 

1.4 We use the following types of cookies:

1. Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. We may use third party analytics tools such as Google Analytics, to help us measure traffic and usage trends and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
3. Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our Website. These third parties are responsible for setting out their own cookie and privacy policies.

1.5 Please see the Annex for more information about the cookies we use on the Website.

2. YOUR COOKIE CHOICES

2.1 We will only place any non-essential cookies on your device if you have given us your consent to do so. You can update your cookie preferences by clicking on the 'Cookies' link at the bottom of our Websites and de-selecting the categories of cookies you no longer wish to use.

2.2 Most browsers will also allow you to control how cookies are used through your browser settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details

1. Cookie settings in Internet Explorer
2. Cookie settings in Firefox
3. Cookie settings in Chrome
4. Cookie settings in Safari web and iOS.

2.3 If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org. We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Section 3 below.

2.4 Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5

3. TRACKING TECHNOLOGIES USED IN OUR EMAILS

3.1 Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you. 

3.2 Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.

3.3 Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

4. INTEREST BASED ADVERTISING

4.1 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of our Website. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of our Website over time so that they may play or display ads of our products or services, on other websites, apps or services you may use (including Facebook), and on other devices you may use.

4.2 Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of our Website and information about which adverts you have seen or clicked on.

4.3 We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

4.4 We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) [and third party cookies (such as the DoubleClick advertising cookie)] or other third party cookies together to inform, optimise, and display ads based on your past visits to our Website.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.    

4.5 We and our third party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you use our Website. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

4.6 You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    

4.7 To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:

1. the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices;
2. the DAA’s resources at www.aboutads.info/choices; and/or
3. Your Online Choices at www.youronlinechoices.eu. 

4.8 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.

4.9 Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.

4.10 Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.

5 CHANGES TO THIS NOTICE

We may update this Cookie Notice from time to time and so you should review this page periodically. When we change this Cookie Notice in a material way, we will update the "last updated" date at the start of this Cookie Notice. Changes to this Cookie Notice are effective when they are posted on this page.

6. CONTACTING US

Please contact support@giraffe360.com if you have any questions, comments and requests regarding this Cookie Notice.

 

ANNEX – COOKIES

Last Updated: 24 August 2020 

Cookie Name	Type of cookie	When is the cookie set?	How long does the cookie stay on my device?	Purposes / Additional information
GPS	Analytical/ Performance	First visit to Website	30 minutes	This cookie is set by YouTube and registers a unique ID for tracking users based on their geographical location.
_ga	Analytical/ Performance	First visit to Website	2 years	These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
_gid	Analytical/ Performance	First visit to Website	1 day
_gat	Analytical/ Performance	First visit to Website	1 minute
_gat_UA-50454236-4	Analytics/ Performance	First visit to Website	1 minute
_fbp	Third Party	First visit to Website	2 months	These cookies are set by Facebook to provide you with more relevant advertisements across Facebook or other digital platforms powered by Facebook advertising after visiting this website.
fr	Third Party	First visit to Website	2 months
sid	Strictly Necessary	First visit to Website	20 years	This cookie allows us to implement our chatbot and analytics functionality in our Content Management System ("CMS").
sessionid	Strictly Necessary	When users login to our CMS	Only for the session	This cookie allows users to login securely to our CMS.
csrftoken	Strictly Necessary	When users login to our CMS	Only for the session	This cookie is designed to help protect a site against at particular type of software attack on web forms.
intercom-session-rhawrz75	Strictly Necessary	First visit to our CMS	1 week	This cookie is used by Intercom messenger so we can keep track of sessions and remember logins and conversations.
_hjid	Analytical/ Performance	First visit to our CMS	1 year	These cookies are used by a website analytics service called Hotjar. They are set to record user behaviour on site – for support and usability testing purposes when we launch new features and functions. For more information about the Hotjar cookies please see help.hotjar.com.
_hjIncludedInSample	Analytical/ Performance	First visit to our CMS	Only for the session