Privacy policy

 

1.     Introduction

1.1.   We are committed to safeguarding the privacy of our App users; in this policy we explain how we will treat your personal information.

 

2.     Collecting personal information

2.1.   We may collect store and use the following kinds of personal information:

(a)        Information that you provide to us when registering with our App.

(b)        Information that you provide to us when using the services on our App, or that is generated in the course of the use of those services.

(c)        Information relating to any purchases you make of our services.

(d)        Information that you post to our App for publication on the Internet.

(e)        Information contained in or relating to any communications that you send to us or send through our App.

(f)         Any other personal information that you choose to send to us.

2.2.   Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

 

3.     Using your personal information

3.1.   Personal information submitted to us through our App will be used for the purposes specified in this policy or on the relevant pages of the website.

3.2.   We may use your personal information to:

(a)        Administer our App and business.

(b)        Personalise our App for you.

(c)        Enable your use of the services available on our App.

(d)        Send you goods purchased through our website.

(e)        Supply to you services purchased through our App.

(f)         Send you non-marketing commercial communications.

(g)        Send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications).

(h)        Provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

(i)         Deal with enquiries and complaints made by or about you relating to our App.

(j)         Keep our App secures and prevents fraud.

(k)        Verify compliance with the terms and conditions governing the use of our App (including monitoring private messages sent through our App private messaging service).

(l)         Other uses.

3.3.   Your privacy settings can be used to limit the publication of your information on our App, and can be adjusted using privacy controls on the App.

3.4.   We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

 

4.     Disclosing personal information

4.1.   We may disclose your personal information to [any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes set out in this policy.

4.2.   We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.3.   We may disclose your personal information:

(a)        to the extent that we are required to do so by law;

(b)        in connection with any ongoing or prospective legal proceedings;

(c)        in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

(d)        to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

(e)        to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4.4.   Except as provided in this policy, we will not provide your personal information to third parties.

 

5.     International data transfers

5.1.   Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

5.2.   Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: [the United States of America, Russia, Japan, China and India].

5.3.   Personal information that you publish on our App or submit for publication on our website may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.

5.4.   You expressly agree to the transfers of personal information described in this Section 6.

 

6.     Retaining personal information

6.1.   This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

6.2.   Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

 

7.     Security of your personal information

7.1.   We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

7.2.   We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

7.3.   All electronic financial transactions entered into through our App will be protected by encryption technology.

7.4.   You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.

8.     Amendments

8.1.   We may update this policy from time to time by publishing a new version on our App.

8.2.   You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3.   We may notify you of changes to this policy [by email or through the private messaging system on our App.

 

9.     Your rights

9.1.   You may instruct us to provide you with any personal information we hold about you.

9.2.   We may withhold personal information that you request to the extent permitted by law.

9.3.   You may instruct us at any time not to process your personal information for marketing purposes.

9.4.   In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

 

10.  Third party websites

10.1.Our App includes hyperlinks to, and details of, third party websites.

10.2.We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

11.  Updating information

11.1.Please let us know if the personal information that we hold about you needs to be corrected or updated.