Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in Privacy Policy and it is important that you read that information.
Before installation of this App or use of our Services through our App, please indicate your consent to our processing of your personal data as described in the privacy policy.
YES I consent.
NO I do not consent.
How you can withdraw consent
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at [email protected] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
Consent to processing Location Data
YES I consent to processing of my Location Data (including details of my current location so that location-enabled Services are activated).
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
Location Data
We are committed to protecting your personal data and respecting your privacy.
Introduction
This policy (together with our Terms and Conditions (Terms) and Cookies Policy) applies to your use of:
This policy is provided in a layered format so you can click through to the specific areas set out below.
[Important information and who we are] [The data we collect about you] [How is your personal data collected] [How we use your personal data] [Disclosures of your personal data] [International transfers] [Data security] [Data retention] [Your legal rights] [Glossary] [Description of categories of personal data]Important Information and Who We Are
We are the controller and are responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
You have the right to make a complaint at any time to the USA regulator for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto our Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data here below.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How Is Your Personal Data Collected?
We will collect and process the following data about you:
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App, the distribution platform or Services and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
How We Use Your Personal Data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances
We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.
Purposes for Which We Will Use Your Personal Data
Purpose / activity
Type of data
Lawful basis for processing
To install the App and Page 6 of 12 register you as a new App user
Identity
Contact
Financial
Device
Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Location
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services
Identity
Contact
Financial
Profile
Device
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products / Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey
Identity
Contact
Device
Profile
Marketing and Communications
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Location
Consent
Necessary for our legitimate interests (to develop our products/Services and grow our business)
Disclosures of Your Personal Data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
International Transfers
Many of our external third parties are based outside of USA so their processing of your personal data will involve a transfer of data outside USA.
Whenever we transfer your personal data out of USA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Data Security
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data Retention
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 1 year then we will treat the account as expired and your personal data may be deleted.
Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us via email.
Glossary
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Persons in the company who provide [IT and system administration services and undertake leadership reporting].
Service providers who provide IT and system administration services.
Professional adviser including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
You have the right to:
Description of Categories of Personal Data