1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Controller and contact details
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 your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth, age, location, gender, identification information or documentation and other identifying data provided by you.
- Contact Data includes address, postal address, email address, telephone numbers, and social media handles.
- Transaction Data includes details of features that you have registered for.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your interests, hobbies, language skills, preferences, feedback, survey and other responses that you share with us.
- Usage Data includes information about how you use our website and features.
- Marketing and Communications Data includes your preferences in receiving marketing material and your communication preferences.
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), unless you voluntarily provide such information. Please use your discretion when providing special categories of personal data to us, and under any circumstances, do not provide special categories of personal data to us unless you thereby explicitly consent to our use of that information for our legitimate business purposes. We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a feature you are using or want to use.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity Data, Contact Data, Profile Data, and/or other data by filling in forms or by corresponding with us by post, phone, email or otherwise, or by using our features, including by participating in any phone call (with us, or with a volunteer Buzzer or older adult). This includes personal data you provide when you:
- apply to use our features;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- use any of the features of the website, including participate in any phone call with us;
- participate in a phone call with a volunteer Buzzer or older adult, all of which are, as stated on our website, recorded;
- or give us feedback or contact us.
- Third parties or publicly available sources. We may receive personal data about you from third party sources, including analytics providers.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the services you have signed up for it.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
See the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data, including on a lawful ground not set out in the table below. Please contact us if you have any questions in that regard.
Purpose/Activity: To register you as a new user. Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you.
Purpose/Activity: To process and provide you with the services. Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary for our legitimate interests.
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey. Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you, (b) Necessary for our legitimate interests (to study how customers use our website, features and services, to develop them and grow our business).
Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation.
Purpose/Activity: To protect our rights and interests and the rights and interests of our users and visitors and the general public, as well as to enforce this policy and our other applicable terms. Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation.
Purpose/Activity: To deliver relevant website content and advertisements and other communications to you and measure or understand the effectiveness of the services and/or any communications we serve to you. Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy).
Purpose/Activity: To analyze or improve our website, products/services, marketing, customer relationships and experiences. Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, to develop or change our services, and to inform our marketing strategy).
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you. Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business).
Promotional offers from us
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, features and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or subscribed for features of our website and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a feature subscription, feature experience or other transactions.
We may allow you to contact your friends, relatives or others to make them acquainted with the website and/or its features, and/or to register them on their behalf and upon their instruction for any of the features of the website. Where this is the case, you expressly acknowledge and agree that you have obtained all necessary authority, consent and permissions to do so, including to use the personal or other information of such person for that purpose and subject to, and to bind such person to, this policy and the Terms.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
- To other users, where it is required in order to operate certain functions for the purpose of service delivery.
- External Third Parties as set out in the Glossary.
6. International transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
7. Data security
We value the security of your data, including but not limited to the personal data collected by us. We have taken steps to help protect the personalized data we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction and any other form of unauthorized processing. However, security cannot be absolutely guaranteed against all threats. We also refer to the relevant provisions set out in the Terms.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymize or pseudonymize 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out herein, please contact us.
You will generally not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month, particularly if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure and enjoyable 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).
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.
External Third Parties means vendors, service providers, professional adviser, agents, contractors, developers, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, market research, surveys, data hosting, fraud detection, telephone and other telecommunication services) on our behalf.
YOUR LEGAL RIGHTS
You may request access to the information we hold about you and request correction or erasure where appropriate. You can do this by emailing us at email@example.com.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes without your consent. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a reasonably structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying only on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features to you.
If the California Consumer Privacy Act (CCPA) applies to your information, we provide these disclosures described in this policy so you can exercise your rights to receive information about our data practices, as well as to request access to, review, update, delate, export and download your information. You can also read more about our data retention periods above, and the process we follow to delete your information.
We only share your information as described in this policy. We may process your information for the purposes described in this policy, which include “business purposes” under the CCPA. These purposes include:
- Protecting against security threats, abuse, and illegal activity. We use and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, we may receive or disclose information about IP addresses that malicious actors have compromised.
- Auditing and measurement. We use information for analytics and measurement to understand how our features are used, as well as to fulfill obligations to any of our partners. We may disclose non-personally identifiable information publicly, including for auditing purposes.
- Maintaining our services. We use information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us.
- Research and development. We use information to improve our services and to develop new products, features and technologies that benefit our users and the public.
- Use of service providers. We share information with service providers to perform services on our behalf, in compliance with appropriate confidentiality and security measures. For example, we may rely on service providers to help provide customer support.
We also use information to satisfy applicable laws or regulations, and disclose information in response to legal process or enforceable government requests, including to law enforcement.
If you have additional questions or requests related to your rights under the CCPA, you can contact us on firstname.lastname@example.org.