Difference between revisions of "Privacy"
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= Privacy = <!--T:1--> | = Privacy = <!--T:1--> | ||
== Introduction == | |||
It is not necessary to make an account with CellMapper to view the data that has already been collected, or to map from a smartphone. However, your data could still be transmitted to the CellMapper service and you still have rights for this data under the laws of the European Union (the General Data Protection Regulation / GDPR hereafter), and all applicable local laws, that will be outlined in this document. | |||
== Personal and Sensitive Information == | |||
CellMapper does not collect any information deemed personal or sensitive by default. Should you wish to contribute to the mapping data, your coarse location ("network information") shall be provided, alongside with your fine location ("current location") will be sent to CellMapper servers. CellMapper does not record any personally identifiable information about your phone that would link the data to an individual. The section below outlines the data collected. | |||
== The data we collect== | |||
By using the CellMapper website your data will be collected in the following ways: | |||
'''Cookies''': Cookies (small amounts of data stored on your computer) which enable CellMapper to easily remember details such as your language settings and your login state are used. By using the website you accept this cookie policy. | |||
Cookies are also used by the analytics and advertising software that we make use of (see below) to track user sessions and for user identification. | |||
'''Analytics and Advertisements''': CellMapper uses analytics software for the purposes of site diagnostics, and to improve the user experience. This data is used to analyse how many users use the website and in what ways. This data is not sold to advertisers or shared with third parties beyond the analytics service. | |||
For the purposes of analytics, a service known as Piwik Analytics is used. We believe that the service is secure, and that reasonable precautions have been taken in regard to the security of your data. | |||
CellMapper also makes use of the Google Advertising platform on the Website and on the Mobile Application. This is done to cover the operating costs of the CellMapper service, and we ask that our users do not block the advertisements that are served to them, and we instead ask them to consider the Cellmapper Premium service which is available at a low cost per month if they wish to do away with advertisements, as a way of supporting the CellMapper project. If you see an advertisement of an inappropriate nature, such as one that contains explicit/adult material, harmful to Computer/Phone material or something else that you consider inappropriate, please feel free to get in touch to voice your concerns, which we will take very seriously. You can also take action via Google to block advertisements such as this. | |||
< | '''<u>OPT-OUT</u>''': If you wish to opt-out from the specific collection of analytics / identifiable data then please enable the “Do Not Track” feature, which will prevent such collection. | ||
We collect the following information when you make an account with us | |||
We | |||
'''Username''': This provides a unique identifier for the data you collect, allowing it to be attributed to you on the CellMapper website. Additionally by registering, you are allowed to locate, and delete towers or cells that have been mapped using the mobile application. Your username will be public and visible to other users on the website, on towers that you have interacted with (mapped whilst logged in, moved or deleted), or on the list of Top CellMapper users. Your username will be used additionally by you to login to the CellMapper website and the CellMapper application. | |||
'''Email Address''': Your email address will be used by us for verification that your account registration is legitimate, and in the event that your password is forgotten, to reset your password so that you can access your account. We also can use your email address to contact you if we need to (examples of this will be if we have received complaints about your actions from another user, or if you are seen to be inadvertently mapping incorrectly). | |||
'''Password''': This is a secret string of letters, numbers or special characters (!@£* etc), known only by you, which you will use to authenticate yourself onto the CellMapper website or the CellMapper application. This will be stored securely on the CellMapper servers using encryption and a technique known as “salting”. CellMapper will not be able to access your password in its “textual” format, and we consider this to be secure. However, as a general rule, we recommend strongly that you use a strong and secure password, which is different from passwords that you use with other services. | |||
'''Profile Picture''': This is loaded from an external service known as Gravatar, where a profile picture uploaded by you will be stored. We believe that this service is to the best of our knowledge secure. If you are already registered to Gravatar with the email address that you sign up to CellMapper with, then your profile picture will be automatically loaded into CellMapper. By using CellMapper, you will also accept the Terms and Conditions of Gravatar. | |||
We | We collect the following information when you upload data from the mobile application to the CellMapper servers, this information is uploaded either manually, when the upload button in the application is pressed, or automatically if the Live Upload feature of the application is enabled: | ||
'''Current Location''': This information includes your latitude, longitude, altitude, and bearing, which provides your precise location in the areas that you have mapped to the CellMapper servers. This will be used for the automatic calculation and processing of data points, in order to estimate the locations of mobile masts, and in order to generate the “Signal Trails”, which form a key part of the CellMapper service. | |||
'''Network Information''': Information about your current cellular network will be transmitted to the CellMapper service, this includes your Mobile Network Code and Mobile Country Code (MNC/MCC) - which identifies your mobile network (e.g Verizon Wireless, T-Mobile, Vodafone UK, Telia Finland, Cosmote GR, TIM Italia), this will be used to ensure that the data you provide is calculated for the right mobile provider. We also collect technical information about the mobile network, which is used for processing the data. This includes LAC/TAC, Cell ID (for example in the GCI format from a 4G LTE network), RSRP/RSCP/RSSI (your signal strength), your RAT (whether you are on 2G/3G/4G) for both serving and neighbouring cells. Additionally depending on what your phone supports we will collect data such as the E/U/ARFCN of your phone, PCI, PSC etc. | |||
'''CellMapper version''': Your phone will upload the version of the CellMapper application that you are using to the CellMapper servers, this will be used for diagnostic purposes and will not be published. | |||
If you | |||
'''CellMapper Account Data''': The data described above relating to a CellMapper | |||
Account will be transmitted if you are signed in. | |||
'''IP-Address''': An identifier relating to the current internet connection you use to | |||
Upload data to CellMapper’s servers will be transmitted, in order to prevent | |||
Vandalism. | |||
'''Android Version Information''': Transmitted by your phone as it talks to our | |||
Servers, this identifies which version of Android you will be using, as well as | |||
Limited information about your device, which will be used for diagnostic | |||
Purposes. | |||
== Under what basis do we collect this information == | |||
Under European Union law we have to provide a clear legal basis for collecting the data that we do. We collect this at CellMapper based on the following two lawful bases, depending on the data being collected: | |||
Legitimate Interest: We believe that we collect data relating to your IP-Address, CellMapper Version, Android Version, as well as Analytics and Advertising data on the basis of “Legitimate Interest”, as this is used mainly for diagnostic purposes, and the prevention of malicious data / fraudulent activity involving CellMapper. The public benefits from this data, as it ensures the wellbeing of the CellMapper platform / project for all users is maintained, and allows for continuous improvement of the platform. We believe that this is a reasonable action to take, as the data is not particularly sensitive, and that people generally expect diagnostic information to be taken. This information will not have a large or common impact on individual users, and users can opt out of providing analytics / advertising data by using the “Do Not Track Feature”. | |||
Consent: We believe that the best legal basis for collecting data relating to your account, as well as the network and location data uploaded, is one of Consent, which is legally defined as an available legal basis under the European Union law. We believe that our implementation of Consent, on the website and on the application is one that can be freely given by users, on registering for the CellMapper service, and one that can be withdrawn. | |||
== Transfer of Information == | |||
CellMapper’s data is transferred outside of the European Union, to Canada for storing and processing. This is done securely, as we make use of OVH data centres for data storage and transfer. We believe that Canada has a strong and robust regulatory environment for data storage. | |||
== Retention of Information == | |||
CellMapper’s information is intended to serve as a long term project mapping the development of mobile networks as they are deployed and changed, as such the data that CellMapper holds is intended to be stored for as long as possible, as a record of mobile networks. Other data not pertaining to this is stored for as long as needed then securely deleted. | |||
== Your Rights pertaining to your Data == | |||
Under European Union Law / the GDPR you have rights relating to your data which we must make you aware of and how they apply to you in the context of CellMapper. | |||
=== Right to be Informed === | |||
You have the right to be informed as to how we collect your data, what data we collect, how we store it and how we retain it. We must explain this to you in plain language, and in a transparent way. We believe we have done this above - if you believe this not to be the case, or if you believe that we are missing appropriate information, please get in touch with us and we would be more than happy to explain/revise this policy to the best of our ability. | |||
=== Right of Access === | |||
You can request a copy of personal data stored with us, either verbally or in writing. We must typically provide this within one month. Please bear in mind that we have the right to request confirmation of identity for this data. Please also bear in mind that you have only the right to request personal data - as much of the data that CellMapper collects can be anonymised completely it is not according to guidelines issued by the authorities personal data. | |||
=== Right to Rectification === | |||
If information we hold about you is wrong, then you can change it. We provide tools to do this yourself for some data, however if you feel that this is not adequate then please get in touch. | |||
=== Right to Erasure === | |||
You have a right for personal data to be deleted. We provide tools to delete your account, however we do not believe collected data falls under this right, as a clear exemption is made within GDPR for archiving data for scientific projects or that is in the public interest - such as for statistical purposes. Erasure of data can serious impede this and as the data can be totally anonymised we do not consider this to fall under this right. | |||
=== Right to Restrict Processing === | |||
In limited scenarios you can request that we restrict the processing of the personal data we hold about you. Please get in touch if you believe this to be the case. | |||
=== Right to Data Portability === | |||
For the purpose of transferring your data to a differing service you may request a copy of your personal data in a commonly used format such as CSV, XML, JSON, or you can request that we transfer it to another data controller. Please get in touch to exercise this right. | |||
=== Right to Object === | |||
According to ICO guidelines you have the right to object to us using your data for direct marketing purposes. As we do not do this, we do not anticipate this being a major issue. However please do get in touch if you feel you have another reason to exercise this right. | |||
Rights related to automated decision making | |||
GDPR specifies that decision making must be done on a lawful basis, we believe that this is covered under the consent given when you upload the data to us. We do not create specific user profiles, and processing is done just on the principle of the CellMapper Mapping Project. Personal data that you upload can also be viewed in your user profile. | |||
=== Other rights === | |||
You have the right to file a complaint with an applicable supervisory authority over our handling of data. | |||
You have the right to withdraw your consent to personal data. | |||
== Contact == | |||
You can contact us about any aspect of CellMapper and specifically about data via email at support@cellmapper.net | |||
Latest revision as of 22:20, 18 December 2020
Privacy
Introduction
It is not necessary to make an account with CellMapper to view the data that has already been collected, or to map from a smartphone. However, your data could still be transmitted to the CellMapper service and you still have rights for this data under the laws of the European Union (the General Data Protection Regulation / GDPR hereafter), and all applicable local laws, that will be outlined in this document.
Personal and Sensitive Information
CellMapper does not collect any information deemed personal or sensitive by default. Should you wish to contribute to the mapping data, your coarse location ("network information") shall be provided, alongside with your fine location ("current location") will be sent to CellMapper servers. CellMapper does not record any personally identifiable information about your phone that would link the data to an individual. The section below outlines the data collected.
The data we collect
By using the CellMapper website your data will be collected in the following ways:
Cookies: Cookies (small amounts of data stored on your computer) which enable CellMapper to easily remember details such as your language settings and your login state are used. By using the website you accept this cookie policy.
Cookies are also used by the analytics and advertising software that we make use of (see below) to track user sessions and for user identification.
Analytics and Advertisements: CellMapper uses analytics software for the purposes of site diagnostics, and to improve the user experience. This data is used to analyse how many users use the website and in what ways. This data is not sold to advertisers or shared with third parties beyond the analytics service.
For the purposes of analytics, a service known as Piwik Analytics is used. We believe that the service is secure, and that reasonable precautions have been taken in regard to the security of your data.
CellMapper also makes use of the Google Advertising platform on the Website and on the Mobile Application. This is done to cover the operating costs of the CellMapper service, and we ask that our users do not block the advertisements that are served to them, and we instead ask them to consider the Cellmapper Premium service which is available at a low cost per month if they wish to do away with advertisements, as a way of supporting the CellMapper project. If you see an advertisement of an inappropriate nature, such as one that contains explicit/adult material, harmful to Computer/Phone material or something else that you consider inappropriate, please feel free to get in touch to voice your concerns, which we will take very seriously. You can also take action via Google to block advertisements such as this.
OPT-OUT: If you wish to opt-out from the specific collection of analytics / identifiable data then please enable the “Do Not Track” feature, which will prevent such collection.
We collect the following information when you make an account with us
Username: This provides a unique identifier for the data you collect, allowing it to be attributed to you on the CellMapper website. Additionally by registering, you are allowed to locate, and delete towers or cells that have been mapped using the mobile application. Your username will be public and visible to other users on the website, on towers that you have interacted with (mapped whilst logged in, moved or deleted), or on the list of Top CellMapper users. Your username will be used additionally by you to login to the CellMapper website and the CellMapper application.
Email Address: Your email address will be used by us for verification that your account registration is legitimate, and in the event that your password is forgotten, to reset your password so that you can access your account. We also can use your email address to contact you if we need to (examples of this will be if we have received complaints about your actions from another user, or if you are seen to be inadvertently mapping incorrectly).
Password: This is a secret string of letters, numbers or special characters (!@£* etc), known only by you, which you will use to authenticate yourself onto the CellMapper website or the CellMapper application. This will be stored securely on the CellMapper servers using encryption and a technique known as “salting”. CellMapper will not be able to access your password in its “textual” format, and we consider this to be secure. However, as a general rule, we recommend strongly that you use a strong and secure password, which is different from passwords that you use with other services.
Profile Picture: This is loaded from an external service known as Gravatar, where a profile picture uploaded by you will be stored. We believe that this service is to the best of our knowledge secure. If you are already registered to Gravatar with the email address that you sign up to CellMapper with, then your profile picture will be automatically loaded into CellMapper. By using CellMapper, you will also accept the Terms and Conditions of Gravatar. We collect the following information when you upload data from the mobile application to the CellMapper servers, this information is uploaded either manually, when the upload button in the application is pressed, or automatically if the Live Upload feature of the application is enabled:
Current Location: This information includes your latitude, longitude, altitude, and bearing, which provides your precise location in the areas that you have mapped to the CellMapper servers. This will be used for the automatic calculation and processing of data points, in order to estimate the locations of mobile masts, and in order to generate the “Signal Trails”, which form a key part of the CellMapper service.
Network Information: Information about your current cellular network will be transmitted to the CellMapper service, this includes your Mobile Network Code and Mobile Country Code (MNC/MCC) - which identifies your mobile network (e.g Verizon Wireless, T-Mobile, Vodafone UK, Telia Finland, Cosmote GR, TIM Italia), this will be used to ensure that the data you provide is calculated for the right mobile provider. We also collect technical information about the mobile network, which is used for processing the data. This includes LAC/TAC, Cell ID (for example in the GCI format from a 4G LTE network), RSRP/RSCP/RSSI (your signal strength), your RAT (whether you are on 2G/3G/4G) for both serving and neighbouring cells. Additionally depending on what your phone supports we will collect data such as the E/U/ARFCN of your phone, PCI, PSC etc.
CellMapper version: Your phone will upload the version of the CellMapper application that you are using to the CellMapper servers, this will be used for diagnostic purposes and will not be published.
CellMapper Account Data: The data described above relating to a CellMapper Account will be transmitted if you are signed in.
IP-Address: An identifier relating to the current internet connection you use to Upload data to CellMapper’s servers will be transmitted, in order to prevent Vandalism.
Android Version Information: Transmitted by your phone as it talks to our Servers, this identifies which version of Android you will be using, as well as Limited information about your device, which will be used for diagnostic Purposes.
Under what basis do we collect this information
Under European Union law we have to provide a clear legal basis for collecting the data that we do. We collect this at CellMapper based on the following two lawful bases, depending on the data being collected:
Legitimate Interest: We believe that we collect data relating to your IP-Address, CellMapper Version, Android Version, as well as Analytics and Advertising data on the basis of “Legitimate Interest”, as this is used mainly for diagnostic purposes, and the prevention of malicious data / fraudulent activity involving CellMapper. The public benefits from this data, as it ensures the wellbeing of the CellMapper platform / project for all users is maintained, and allows for continuous improvement of the platform. We believe that this is a reasonable action to take, as the data is not particularly sensitive, and that people generally expect diagnostic information to be taken. This information will not have a large or common impact on individual users, and users can opt out of providing analytics / advertising data by using the “Do Not Track Feature”.
Consent: We believe that the best legal basis for collecting data relating to your account, as well as the network and location data uploaded, is one of Consent, which is legally defined as an available legal basis under the European Union law. We believe that our implementation of Consent, on the website and on the application is one that can be freely given by users, on registering for the CellMapper service, and one that can be withdrawn.
Transfer of Information
CellMapper’s data is transferred outside of the European Union, to Canada for storing and processing. This is done securely, as we make use of OVH data centres for data storage and transfer. We believe that Canada has a strong and robust regulatory environment for data storage.
Retention of Information
CellMapper’s information is intended to serve as a long term project mapping the development of mobile networks as they are deployed and changed, as such the data that CellMapper holds is intended to be stored for as long as possible, as a record of mobile networks. Other data not pertaining to this is stored for as long as needed then securely deleted.
Your Rights pertaining to your Data
Under European Union Law / the GDPR you have rights relating to your data which we must make you aware of and how they apply to you in the context of CellMapper.
Right to be Informed
You have the right to be informed as to how we collect your data, what data we collect, how we store it and how we retain it. We must explain this to you in plain language, and in a transparent way. We believe we have done this above - if you believe this not to be the case, or if you believe that we are missing appropriate information, please get in touch with us and we would be more than happy to explain/revise this policy to the best of our ability.
Right of Access
You can request a copy of personal data stored with us, either verbally or in writing. We must typically provide this within one month. Please bear in mind that we have the right to request confirmation of identity for this data. Please also bear in mind that you have only the right to request personal data - as much of the data that CellMapper collects can be anonymised completely it is not according to guidelines issued by the authorities personal data.
Right to Rectification
If information we hold about you is wrong, then you can change it. We provide tools to do this yourself for some data, however if you feel that this is not adequate then please get in touch.
Right to Erasure
You have a right for personal data to be deleted. We provide tools to delete your account, however we do not believe collected data falls under this right, as a clear exemption is made within GDPR for archiving data for scientific projects or that is in the public interest - such as for statistical purposes. Erasure of data can serious impede this and as the data can be totally anonymised we do not consider this to fall under this right.
Right to Restrict Processing
In limited scenarios you can request that we restrict the processing of the personal data we hold about you. Please get in touch if you believe this to be the case.
Right to Data Portability
For the purpose of transferring your data to a differing service you may request a copy of your personal data in a commonly used format such as CSV, XML, JSON, or you can request that we transfer it to another data controller. Please get in touch to exercise this right.
Right to Object
According to ICO guidelines you have the right to object to us using your data for direct marketing purposes. As we do not do this, we do not anticipate this being a major issue. However please do get in touch if you feel you have another reason to exercise this right. Rights related to automated decision making GDPR specifies that decision making must be done on a lawful basis, we believe that this is covered under the consent given when you upload the data to us. We do not create specific user profiles, and processing is done just on the principle of the CellMapper Mapping Project. Personal data that you upload can also be viewed in your user profile.
Other rights
You have the right to file a complaint with an applicable supervisory authority over our handling of data. You have the right to withdraw your consent to personal data.
Contact
You can contact us about any aspect of CellMapper and specifically about data via email at support@cellmapper.net