• 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: Michael Neligan – CEO
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 (www.ico.org.uk). 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:
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
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
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.