Effective Date: 01 January 2018 Notice Version: 1.0
Data Controller Contact Information
1 Bell Street, Maidenhead, Berkshire, SL6 1BU email@example.com
This document governs the privacy notice of our mobile app.
Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our mobile app.
When using our website and submitting personal data to us, you may have certain rights under the General Data Protection Regulation (GDPR) and other laws. Depending on the legal basis for processing your personal data, you may have some or all of the following rights:
The right to be informed
You have the right to be informed about the personal data we collect from you, and how we process it.
The right of access
You have the right to get confirmation that your personal data is being processed and have the ability to access your personal data.
The right to rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete.
The right to erasure (right to be forgotten)
You have the right to request the removal or deletion of your personal data if there is no compelling reason for us to continue processing it.
The right to data portability
The right to restrict processing
You have a right to ‘block’ or restrict the processing of your personal data. When your personal data is restricted, we are permitted to store your data, but not to process it further.
You have the right to request and get your personal data that you provided to us and use it for your own purposes. We will provide your data to you within 30 days of your request. To request your personal data, please contact us using the information at the top of this privacy notice.
The right to object
You have the right to object to us processing your personal data for the following reasons:
Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
Direct marketing (including profiling); and
Processing for purposes of scientific/historical research and statistics.
Rights in relation to automated decision-making and profiling.
Automated individual decision-making and profiling
You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Filing a Complaint with Authorities
You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
For details about your rights under the law, visit https://goo.gl/F41vAV
‘Non-personal data’ (NPD) is information that is in no way personally identifiable.
‘Personal data’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
Topics Covered in Our Privacy Notice
Information We Collect
How Your Information Is Used
A “member” or “user” is someone who has registered to download our mobile app and use our Services or buy our products.
Retaining and Destroying Your PD
Updating Your PD
Revoking Your Consent for Using Your PD Protecting the Privacy Rights of Third Parties Do Not Track Settings
Links to Other Websites
Protecting Children’s Privacy
Our Email Policy
Our Security Policy
Use of Your Credit Card
Transferring Personal Data from the European Union Changes to Our Privacy Notice
Information We Collect
Generally, you control the amount and type of information that you provide to us when using our mobile app.
Our Legal Basis for Collecting and Processing Your Personal Data (PD)
Our legal basis for collecting and processing your personal data (PD) is based on and the necessity for the performance of a contract or to take steps to enter into a contract.
What Happens if you Don’t Give Us Your Personal Data (PD)
If you do not provide us with enough PD, we may not be able to provide you with all the features of our mobile app.
We collect your PD in the following ways:
We automatically receive information from your browser or mobile device. This information includes the name of the website from which you entered our mobile app, if any, as well as the name of the website you’ll visit when you leave our mobile app. This information also includes your IP address and the proxy server you use to access the Internet, your Internet serviceprovider’s name, your web browser type, the type of mobile device, your operating system, and data about your activity when using our mobile app. We use all this information to analyze trends among our users to help improve our mobile app.
At User and Member Registration
When you register as a user or member, we collect your name, email address, and other information listed.
When Buying Products or Services
If you buy products or services from us, we collect your first and last name, email address, physical address, credit card or other payment information, phone number, and other information listed.
In App Forms
Our mobile app may use in app forms. The information you enter into these in app forms may contain PD.
Collecting Your Location Information
When you use our mobile app and services, we may collect and process information about your actual physical location. We use several technologies, like GPS and IP tracking, to determine your location. These technologies may also provide us with information about nearby cell towers, Wi-Fi access points, and other devices.
Strictly Necessary Cookies
These cookies collect information about the use of the mobile app, such as pages visited, traffic sources, users’ interests, content management, and other measurements.
These cookies enable the mobile app to remember a user’s choices – such as their language, user name, and other personal choices while using the mobile app. They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos while using the mobile app.
These cookies can be used to improve a mobile app’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies
permission to place, store, and access some or all the cookies described below on your mobile
These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements to you that are related to your interests. You will see less advertising if you disable these cookies.
These cookies allow mobile apps to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they use a mobile app. Session cookies also permit users to be recognized as they navigate a mobile app so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
These cookies are stored on a user’s device in between browser sessions, which allows theuser’s preferences or actions across a website (or, in some cases, across different websites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a mobile app or to target advertising to them.
Identifying the areas of our mobile app that you have visited
Personalizing content that you see on our mobile app
Our mobile app analytics
Remarketing our products or services to you
Remembering your preferences, settings, and login details
Targeted advertising and serving ads relevant to your interests
Allowing you to post comments
Allowing you to share content with others and with social networks
We may also use a technology called web beacons to collect general information about your use of our mobile app and your use of special promotions, emails, or text messages. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails and use our services. Web beacons also help us to understand the behavior of our customers and visitors.
Google Ad and Content Network Privacy Notice
to our users based on their visits to our mobile app and other websites on the Internet. Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting http://www.aboutads.info/choices/
Google Analytics Privacy Notice
We use Google Analytics to collect information about the use of our mobile app. Google
We use the information we get from Google Analytics to improve our mobile app. Google Analytics collects
only the IP address assigned to you on the date you visit our mobile app, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our site, the cookie cannot be used by anyone but Google. You can prevent Google Analytics from using your information by opting out at this link: https://tools.google.com/dlpage/gaoptout
Why am I seeing ads by Google for products I’ve viewed?
Analytics collects information from users such as age, gender, interests, demographics, how
often they visit our mobile app, what pages they visit, and other information.
How Your Information Is Used
We use the information we receive from you to:
Provide our products and services
Personalize and customize our content
Make improvements to our mobile app
Contact you with updates to our mobile app
Resolve problems and disputes
Contact you with marketing and advertising
that we believe may be of interest to you
Communications and Emails
When we communicate with you about our mobile app, we will use the email address you provided when you registered as a member or user. We may also send you emails with promotional information about our mobile app or offers from us or our affiliates unless you have opted out of receiving such information. You can change your contact preferences at any time through your account or by sending us an email with your request to: firstname.lastname@example.org
Sharing Information with Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your non-personal data (NPD), which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may provide your PD to third-party service providers we hire to provide services to us. These third- party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
We also share your information with third parties by using an Application Program Interface“API.” Such third parties may include but are not limited to Facebook, LinkedIn, Twitter, YouTube.com and Google.com. This sharing of information helps us provide you with a better experience when using our mobile app and services.
Sharing Information with Facebook and Google for Marketing Purposes
We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD, for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours, this helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our website and agreeing to our privacy notice, you are giving your consent for your PD to be used for the marketing purposes described within this section.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or another legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the mobile app to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business. We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Community Discussion Boards
Our mobile app may offer the ability for users to communicate with each other through online community discussion boards or other mechanisms. We do not filter or monitor what is posted on such discussion boards. If you choose to post on these discussion boards, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you choose to disclose your PD through such postings. Also, PD you post on our mobile app for publication may be available worldwide by means of the Internet. We cannot
prevent the use or misuse of such information by others.
Retaining and Destroying Your (PD)
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic form, paper form, or a combination of both. When your information is no longer needed, we will destroy, delete, or erase it.
Updating Your (PD)
You can update your PD using services found on our mobile app. If no such services exist, you can contact us using the contact information found at the top of this notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.
Revoking Your Consent for Using Your PD
You have the right to revoke your consent for us to use your PD at any time. Such an opt out will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures to affiliates and business partners, (ii) disclosures to third-party service providers that provide certain services for our business, such as credit card processing, computer system services, shipping, data management services, (iii) disclosures to third parties as necessary to fulfill your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as otherwise required to be made under applicable law, (v) previously completed disclosures to third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions you may choose to enter, or third-party offers you may choose to accept. If you want to revoke your consent for us to use your PD, send us an email with your request to: email@example.com
Protecting the Privacy Rights of Third Parties
If any postings you make on our mobile app contain information about third parties, you must make sure you have permission to include that information in your posting. While we are not legally liable for the actions of our users, we will remove any postings about which we are notified, if such postings violate the privacy rights of others.
Do Not Track Settings
Some web browsers have settings that enable you to request that we do not track your movement within our mobile app. Our mobile app does not obey such settings when transmitted to and detected by our mobile app. You can turn off tracking features and other security settings in your browser by referring to your browser’s user manual.
Links to Other Websites
Our mobile app may contain links to other websites. These websites are not under our control and are not subject to our privacy notice. These websites will likely have their own privacy notices. We have no responsibility for these websites and we provide links to these websites solely for your convenience. You acknowledge that your use of and access to these websites are solely at your risk. It is your responsibility to check the privacy notices of these websites to see how they treat your PD.
Protecting Children’s Privacy
Even though our mobile app is not designed for use by anyone under the age of 16 (child), we realize that a child under the age of 16 may attempt to access our mobile app. We do not knowingly collect PD from children under the age of 16. If you are a parent or guardian and
believe that your child is using our mobile app, please contact us. Before we remove any information, we may ask for proof of identification to prevent malicious removal of account information. If we discover that a child is accessing our mobile app, we will delete his/her information within a reasonable period of time. You acknowledge that we do not verify the age of our users nor do we have any liability to do so.
Our Email Policy
You can always opt out of receiving further email correspondence from us or our affiliates. We will not sell, rent, or trade your email address to any unaffiliated third party without your permission except in the sale or transfer of our business, or if our company files for bankruptcy.
Our Security Policy
We have built our mobile app using industry-standard security measures and authentication tools to protect the security of your PD. We also maintain technical and physical safeguards to protect your PD. When we collect your credit card information through our mobile app, we will encrypt it before it travels over the Internet using industry-standard technology for conducting secure online transactions. Unfortunately, we cannot guarantee against the loss or misuse of your PD or secure data transmission over the Internet because of its nature. We strongly urge you to protect any password you may have for our mobile app and to not share it with anyone. You should always log out of our mobile app when you finish using it.
Use of Your Credit Card
You may have to provide a credit card to buy products and services from us. We use third-party billing services and have no control over these services. We use our commercially reasonable efforts to make sure your credit card number is kept strictly confidential by using only third- party billing services that use industry-standard encryption technology to protect your credit card number from unauthorized use. However, you understand and agree that we are in no way responsible for any misuse of your credit card number.
Transferring Personal Data from the European Union
(PD) that we collect from you may be stored, processed, and transferred between any of the countries in which we operate, specifically the United Kingdom, United States of America, Mexico, Russia, Australia, Republic of South Africa and Ireland. The European Union has not found the United States and some other countries to have an adequate level of protection of PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the GDPR. For European Union customers and users, with your consent, your PD may be transferred outside the European Union to the United States. We will use your PD to provide the goods, services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights. Wherever we transfer, process or store your PD, we will take reasonable steps to protect it. We will use the information we collect from you in accordance with our privacy notice. By using our website, services, or products, you agree to the transfers of your PD described within this section.
Changes to Our Privacy Notice
We reserve the right to change this privacy notice at any time. If our company decides to change this privacy notice, we will post those changes on our mobile app so that our users and customers are always aware of what information we collect, use, and disclose. If at any time, we decide to disclose or use your PD in a method different from that specified at the time it was collected, we will provide advance notice by email (sent to the email address on file in your account). Otherwise, we will use and disclose our users’ and customers’ PD in agreement with the privacy notice in effect when the information was collected. In all cases, your continued use of our mobile app, services, and products after any change to this privacy notice will constitute your acceptance of such change.
Questions About Our Privacy Notice
Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
“Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
If you have any questions about our privacy notice, please contact us using the information at the top of this privacy notice.
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