Updated 5 Oct 2020.
Right to object
Please note, under the GDPR, Article 21, you have the right to object to the processing of
personal information concerning you. You can do this anytime from the Contact us menu option. If you do object, we can no longer process
your personal data unless we demonstrate compelling legitimate grounds for the processing
which overrides your interests, rights and freedoms or for the establishment, exercise or defence
of legal claims.
Now please read the remainder of this page describing how we use and safeguard user
data before you provide us with any of your personal information…
Introduction
In the context of the Imprints service (according to the GDPR article 4) the
term controller means the natural or legal person who determines the purposes
and means of the processing of personal data. The name of the controller for the
Imprints service is Kieran White. You can contact him using the Contact us screen.
The GDPR allows for a number of legal bases for the processing of
personal information. The basis for our processing of personal information is
legitimate interest. The purpose of our processing this information is to provide a
service to allow people to create drawings and then share them publicly online in a
browser. The section Personal information below describes the specific reasons
for requiring each type of personal information we collect and store. The particular
legitimate interest pursued by the controller is the facilitation of the practice of
rights listed in the Charter of Fundamental Rights of the European Union namely
Article 13, Freedom of the arts and sciences and where applicable Article
11, Freedom of expression and information.
We rely on a data processor to provide hosting for the website and they will have
access to any personal information stored in the server database (in whatever form
that may be) that is necessary to perform that function but we do not pass your
personal information to other third parties. Of the data we store, we encrypt the
personal information we know to be most sensitive. All data transmitted from both
clients and server is encrypted. More details are provided later on in this page.
We process personal information of users that have registered with the Android
app. Users do have the ability to alter or remove some personal information from
within the Android app, but a notable exception to this is the user's e-mail
address. It is not currently possible to update your e-mail address within the app. If
you wish to update your e-mail address (or you are having difficulty making other
changes yourself within the app) you'll need to send us a message (using the Contact
us screen) requesting that we perform the update on your behalf. Please be aware that
before making any change to your personal data on your behalf we'll need to verify
that you are who you claim to be.
Another scenario where we process personal information is where someone sends us a
message using the Contact us screen of the website. Once we resolve the issue raised
by them or have determined that we are not in a position to resolve their issue, we
will remove any personal information from the system that was added for the
sole purpose of creating or tracking their ticket.
We will delete the personal information of anybody who requests that we do so if
their identity can be confirmed. A natural consequence of deleting the personal
information of a registered user is that their account and any drawings created by him
or her will be removed from the system. If we have to delete the personal information
of somebody who has raised an issue using the Contact us screen then we will no longer
be able to reply to their earlier messages (due to not being is possession of their
e-mail address).
There is another way in which personal information can be recorded on our server:
whenever someone visits our website or the Android app interacts with our server, a
record of their visit or interaction is saved to logs on the server for debugging and
security purposes. These will contain some information that could be considered
personal (e.g. IP addresses, but also possibly some of the types personal information
that we describe on this page). We encrypt any additions to these logs daily and
retain them for 100 days.
The GDPR defines a number of user rights:
- the right to request from the controller access to and rectification or erasure of
personal data or restriction of processing concerning the data subject or to object to
processing as well as the right to data portability;
- the right to lodge a complaint with
a supervisory authority.
We are also required to inform you that providing us with any personal
data is not a statutory or contractual requirement. Nor is providing us with personal
information required for entry into a contract (as there is no contract). However
without providing us with at least some personal information (namely an e-mail address
and password) we will be unable to identify and authenticate you as a user and that
will prevent you from creating art that you can publish on the Imprints website.
Treatment of your information
The only information we process (collected either via the web-browser or
Android client) or store is the minimum required for Imprints to operate. We take
steps where it's feasible to reduce the likelihood that third-parties (including our
chosen hosting provider), will be able read your personal data after it leaves your
device (e.g. your phone, tablet or computer).
Imprints is not a money-making venture, let alone a self-sustaining one. We cannot
unfortunately guarantee that drawings and any other data uploaded to our server will
be retained for any period of time except insofar as is legally required. Neither can
we make any commitment to operate the service for any minimal period of time.
The occasions when a user's data is vulnerable to third-party
eavesdropping after it has been transmitted from your own device can broadly be
categorised into times when the information is at rest and when the information is in
transit. The former refers to the persistent storage of information on servers and the
latter to the period when data is being transferred from your own devices to our
server and vice versa. We describe how we deal with these two contexts below.
Information at rest
Personal information
If you have any GDPR requests you can send them to us
using the Contact us screen.
Next, for each type of personal information listed, we describe why we
process it, when we obtain it, what precautions we take to protect it and how long we
retain it:
E-mail address
We use e-mail addresses whenever we need to distinguish one individual as they
interact with our service (either through the website or the Android editor)
from others. We will not send you marketing e-mails and we will not share your
e-mail address with anyone. However, we will send you an e-mail when or if:
- you are registering an account; in order to validate your identity,
- you are locking your account or resetting your password (again as a way to validate your identity),
- you have sent us a message using the website's Contact us page,
- we need to notify you of a data-breach or
- we need to permanently shutdown the Imprints service or need to remove some
of your data from the server in contexts or for reasons not described elsewhere
in this document.
An e-mail address is required when:
- creating an account or logging into an existing account in the Android
app,
- a user resets his or her password,
- a user locks his or her account on the website and
- a user contacts us via the Contact us form on the website, thereby creating
a support ticket.
For the first three uses above, we encrypt and store the e-mail address, but we
also store its hash. The hash and encrypted e-mail address are
retained only as long as the person has an account with us. We also send an
e-mail to the user when they are creating an account, resetting their password
or locking their account. The e-mail is part of a process we use to confirm the
person's identity.
If you wish to delete your account, please send us a message to this effect
from the website's Contact us screen.
When someone sends us a message using the Contact us form, we encrypt and store
their e-mail address so that we can respond. This record of the e-mail address
is removed from the database as soon as the support ticket is closed. We also
send a message to the provided e-mail address informing the user of the ticket
reference number. This e-mail is CCed to another address that we are monitoring
and this is what notifies us that a new support ticket has been created. The
copied e-mail will be deleted when the ticket is closed.
-
Password
A password is the primary means we have of determining that a user is the same
person as registered previously with a given e-mail address.
A password is requested when a person:
- registers themselves as a new user when installing the Android editor for
the first time,
- goes to change his or her password in the User Settings screen of the
Android editor (for this we require both the old and new passwords) or
else
- goes to set his or her password after first resetting it in the Android
editor.
This password is not saved anywhere. Instead we generate a random secret which
is encrypted using a key derived from the password. That encrypted secret is
what is saved to the server database. If the user re-enters the same password
later (e.g. when installing the Android editor on a new device), the key derived
from it will be the same as before and can successfully decrypt this saved date,
demonstrating that the correct password was entered. As we do not store your
password, if the server database if ever compromised you can be assured that
your password hasn't been leaked.
-
Pseudonym
When a user is performing a keyword search for pictures on the website, a list
of published pictures is returned showing a thumbnail of each, the picture's
title and the pseudonym of the artist. Imprints needs to display something as
the pseudonym, however it is not necessary for the user to provide one. In the
absence of a user-provided pseudonym the website will simply display a default
placeholder instead.
The user can provide a pseudonym at anytime when using the Android editor by
opening the User Settings menu option. If a pseudonym has not been set, he or
she will be reminded to provide one whenever a picture is published.
Despite pseudonyms being plainly visible in search results, we do encrypt this
information in our database.
The user can change his or her pseudonym in the editor at any time and the new
pseudonym will replace the previous one in the server database.
-
Ticket message
When users require support they can send us a message using the Contact us
screen. This creates a support ticket. These messages and the e-mail address
submitted with them on the Contact us screen are stored on the server database,
but are encrypted before doing so. The messages and e-mail addresses are deleted
when the ticket is closed. The ticket's creator can choose to have the ticket
closed at any time before the issue is resolved and we will abide by their
wishes — also removing any personal information that was stored as a result of
the ticket.
It is likely that we will respond to a new ticket by e-mail. Any e-mails that
are sent over and back in relation to a ticket will deleted once the ticket
itself is closed.
Because there will be times when we must close a ticket without first resolving
the issue raised by the user, we will ensure that there is an anonymised record
on an internal tracking system of issues created on our ticketing system. This
allows us to continue our investigation into such issues. These anonymised
records will not be deleted when their associated tickets are closed. Once the
ticket is closed it is not possible to for us contact the user that created
it.
-
IP address
Information including your IP address is stored in our logs when you interact
with the Imprints website and when, after installing the Android app, it
interacts with our server. This is done to facilitate debugging (including
bandwidth and latency management) and for security. Once a day any unencrypted
logging information is encrypted. In addition logs are deleted after 100 days.
There are other types of information submitted by users that are
potentially personal. This is free-form user-submitted content which could possibly
include personal information because we don't currently attempt to prevent its
inclusion. Next we describe these types of data that we process and store, what we
use it for, when we obtain it from the user and how long we retain it:
Pictures
The Android editor will attempt to upload all created pictures to the server,
even those that are not currently published. However, the only pictures viewable
in a browser or listed in search results on the website are those whose creator
has chosen to make available to the general public using the Publish facility in
the Android editor. The creator of a published picture can also choose the
retract it with the editor. Once the server has been informed of the retraction
during synchronisation that picture will not appear in subsequent search results
or be viewable in a browser (unless later republished).
Any of the pictures stored on our server database comprise lists of vertex,
colour, opacity (i.e. transparency) and stroke width definitions that are not
encrypted. This because the quantity of data that comprises a single picture
tends to be much larger than the textual records of information that we do
encrypt (e.g. e-mail addresses). Consequently we were concerned that
encrypting picture data might impose a significantly large burden on our
server and reduce our ability to fully utilise that data. We need to store
picture data on the server in order to display drawings in the browser or make
them available to the picture's creator for editing in the Android editor,
possibly on a number of different devices.
There are also thumbnail previews of pictures. These are also stored in the
server database, but again are not encrypted. They can be displayed in search
results in the browser (if the picture is currently published) but are also
essential in navigating the Android editor's interface.
The Android editor provides an interface that records all this information
while the user draws a picture and then it uploads the information to the
Imprints server during synchronisation.
If it comes to our attention that a picture is inappropriate or could bring
us into conflict with the law we may render it unavailable for viewing in a
browser (including listing it in search results). Subsequently only the artist
will be able to view the picture, once retracted, in the editor. If this
happens to one of your pictures and you want to ensure your drawing is
publically available again, please contact us and we will work you in your
efforts to resolve our concerns. Hopefully then we will be able to restore
public access to the picture.
A user can delete one of his / her pictures from within the Android
editor. If the picture if currently published, it must first be retracted. After
deleting the picture in the editor, it will be removed from the server database
on the next synchronisation update.
Titles of pictures
Picture titles are encrypted on the server. The title of a drawing, a simple
text string, will be displayed in the search results presented in response to
a keyword search by the user. The title of the currently rendered picture will
also be displayed if a user clicks on the information icon on the
website. Additionally, the Android editor overlays the title of each picture
on its thumbnail representation in one of the editor's screens.
At any point during the editing of a picture (while it's not published) the
user can set its title. The title will subsequently be uploaded to the server
during one of its periodic synchronisation operations. Strictly speaking the
user does not need to set a title. In the absence of a user-defined title, the
default is an automatically generated time / date stamp. If the user retains
this default, it limits the ability of other users to encounter the picture
during a casual keyword search because search results are ranked solely on
basis of keywords in the title that also occur in the query.
The title of a picture only exists while the picture itself does. When the
picture is erased from the server database, so too is the title. If the user
changes the title of a picture and that new title is uploaded to the server
during a synchronisation operation, it will replace the previous title, which
will in effect be deleted at that time.
There is also an index that tracks the picture titles that contain individual
terms and records a count of the number of times each term is used in these
titles. The index doesn't actually contain the terms themselves, rather the
server extracts the stem of each term and converts these
to hashes. It
is these hashes that are stored in the database. The index is updated when a
picture title is changed or a picture is deleted or made unavailable to the
public.
Other data
Next we describe various other types of user-submitted data we
process, what we use it for, when we obtain it from the user and how long we retain
it:
Search terms
When a visitor to the website submits a query the search keywords are sent to
the server. Their stems are converted to hashes and stored so that the list
of results can be compiled. Once these results have been returned or the query
is terminated for any other reason, the hashes and any intermediate
calculations and results are removed from the database.
Backups
Encrypted backups of all data on the server are created daily and
retained for 10 days.
Information in transit
Encryption of communications / Server authentication
All communication between browser and server and between the Android
editor and server is Secure Sockets Layer (SSL) encrypted. When a user visits the
Imprints website he / she can check the identity of its creators and verify that the
connection is encrypted using the facilities provided by the browser. The Android
editor will also not connect to the server if its identity cannot be trusted or if
messages between the editor and server are not encrypted.
Client authentication
There are numerous types of messages sent to the server. Some of these
messsages are of a type that can potentially make changes to a registered user's
data and the server will only act on those messages in the following circumstances:
In the case of messages expected to come from the Android editor the
identity of the person who installed the app must be proven by:
- the presence of the correct digital signature or
- (for a limited set of message types) demonstrating access to that person's
registered e-mail account.
If a message is of the types usually sent from a web-browser and can
result in the alteration of user data, the identity of the person presently
operating the browser must be verified by demonstrating access to a specified
registered e-mail account.
Cookies
Unlike the other types of information listed above, cookies are managed
by your browser. They are usually small items of information associated with
particular websites or webpages. The Imprints website only creates a single cookie
called dpPrompt and this has the purpose of recording whether you have viewed
our Data protection dialog box. If you have, the website doesn't display that dialog
box again unless this data protection document has been updated or the dpPrompt cookie
expires, which it will do after 365 days. This cookie and the information it conveys
is never sent to our server.
Data breaches
Where a personal data breach is found to have occurred we will notify the the
competent supervisory authority (i.e. the Irish Data Protection Commission). If the
breach is likely to result in a high risk to the rights and freedoms of some of our
users we will (subject to the guidance of the Data Protection Commission or other
relevant authorities) notify those who might be affected, by e-mail.
