• visit our website www.walksafe.io (regardless of where you visit it from) (the “Website”)
• use the WalkSafe app (the “App”); or
• use the service you connect to via the App and the content we provide to you through it ("Service")
and tell you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Please be aware that internet transmissions are never completely private or secure and that any message or information you send using the App or any Service may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Chaperhome Limited
Name or title of data privacy manager: Data Privacy Manager
Email address: firstname.lastname@example.org
Postal address: Watergate House, 85 Watergate Street, Chester, England, CH1 2LF
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 12th March 2019 and historic versions can be obtained by contacting us.
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.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
INFORMATION YOU GIVE US ("SUBMITTED INFORMATION")
This is information you give us about you by filling in forms on the App, or by corresponding with us (for example, by email). It includes information you provide when you register to use the App, download or register the App, subscribe to or use any of our Services, and when you report a problem with the App or our Services. If you contact us, We will keep a record of that correspondence. The information you give us may include your name, address, date of birth, email address and phone number, username, password and other registration information.
INFORMATION WE COLLECT ABOUT YOU AND YOUR DEVICE
Each time you use our App we will automatically collect the following information:
• technical information, including unique device identifier and time zone settings ("Device Information");
• information stored on your Device, including contact information, lists of friends (only where such friends have downloaded and signed up to use the App and also have your telephone number), login information, and push notification service device identifiers ("Content Information"); and
• we also use GPS technology to determine your current location ("Location Information"). Some of our location-enabled Services require your personal data for the feature to work. However, we want you to be able to control what we do with your data so if you do not wish to use the particular feature, you can withdraw your consent to using this feature at any time by turning off location services on your device.
We use information held about you in the following ways and rely on the following legal bases for doing so:
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but We may provide them with anonymous aggregate information about our users (for example, We may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). This anonymous data is outside the scope of UK data protection laws.
We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1).
We will use the personal data We have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience and the legal basis for this is our legitimate business interest in providing services to advertisers whose fees will fund the App and the Services.
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 (for example, to provide you with goods or services). In this case, we may have to cancel the Service but we will notify you if this is the case at the time.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties in the following circumstances:
• in the event that We sell or buy any business or assets, in which case We will disclose your personal data to the prospective seller or buyer of such business or assets (and our legal basis for doing this will be our legitimate interest selling or buying such business or assets);
• if We or substantially all of our assets are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets (and our legal basis for doing this will be our legitimate interest selling or buying such business or assets);
• if We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request (in which case our legal basis will be the compliance with such obligation or request);
• in order to:
o enforce or apply these Licence Terms and Conditions and other agreements or to investigate potential breaches (in which case our legal basis will be our legitimate interest in enforcing ort applying our contractual rights); or
o protect the rights, property or safety of our customers, or others (in which case our legal basis will be our legitimate business interests in protecting such rights, properly or safely). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
THIRD PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the App and checking or unchecking relevant boxes to adjust your marketing preferences or 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 product/service purchase or use.
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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
WHERE WE STORE YOUR PERSONAL DATA
Where We have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Where you use your Facebook credentials to log in to the App, you are responsible for keeping those credentials confidential. We ask you not to share such credentials with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to us throughout our App and any transmission or use of the App is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
Details of retention periods for different aspects of your personal data are available on contact.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows:
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• 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. 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 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 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on the details above.
NO FEE USUALLY REQUIRED
You will 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 may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.
The App and/or the Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, 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.