POLICY ON PRIVACY, DATA, COOKIES AND MARKETING COMMUNICATIONS
Date of Last Revision: August 2014
Please read the following carefully to understand Givvit’s views and practices regarding your personal data and how we will treat it. STARTLED FROG LIMITED (“Givvit”, “we” or “us”) is committed to protecting your privacy.
The App enables friends to send and receive treats in the form of gift codes and vouchers (or similar) which can be redeemed for specified products or services (“Treats”). Treats are issued by retailers (known as “Treat Partners”) and distributed by the App. Treats are redeemable for goods and services at Treat Partner’s premises or online stores.
In summary, we require permission to access your data in the following areas for the associated reasons outlined –
- Personal data so we can verify your identity, authorise your advice, correspond with you and from time to time tell you about our product and services
- Access to contacts on your phone or social media to allow you to invite friends to Givvit and send Treats to other users
- We require the use of push notifications to communicate with you including notifying you when you have received a Treat
- Access to location data so you can find the nearest redemption point to help you redeem your Treat
- Access to location data so that we can in some cases process and identify when redemption has taken place
- We will only share your data with our Treat Partners and to enhance the usability of the App
Your attention in particular is drawn to paragraph 10 (Location data) below.
- We will only use information collected about you in accordance with the Data Protection Act 1998.
- The App is intended for use by those 13 years of age or older. If we learn that a person under the age of 13 has provided us with personal information, we will take steps to delete such information as soon as possible.
- When you access the App through an App Store depending on your specific privacy settings with that App Store we may be able to access certain information from your account or the information given by you to that App Store. You are advised to review your privacy settings with any App Store.
- By accessing the App through the App Store you authorise us to collect, store, access and use that information which you have agreed the App Store may provide to us.
- The App creates a social community for its users, where your location and that of other users may be publically shared within the App. Your location data is sent to us when you install the App and each time you use the App, and if you choose, by amending the privacy settings, so that we may send you push notifications.
- Your location in the future may be made available on a general information basis to other users, and does not provide other users with your detailed location.
- We collect your location data to understand how users use the App and to provide you with the social networking functionality made available through the App (which may include from time to time, advertising and offers based on your location). When you check into a location on the App, you will be sharing that information with other App users to help create the App social network and to increase engagement on the App.
- By using the App you accept and agree to us obtaining, storing and using your location data.
- We store your location data which is obtained via the App for as long as is necessary for us to provide the services of the App to you, or otherwise until you delete the App and notify us at email@example.com that you wish for the data to be deleted.
- In addition during your use of the App you agree that the following terms will apply:
- We may ask you for certain information and you may submit personal data to us when processing any correspondence you send us (such as your name, username, email address, and contact details).
- We may also record which parts of the App you use as part of general user patterns. This information will be kept securely in accordance with an internal security policy and may be used:
- to generally run, operate and maintain the App;
- for internal record keeping;
- to improve the App;
- to notify and inform users of updates, new App and / or promotional offers;
- to enable and process your use of and generally run the App; and
- to collect, where applicable, achievements and goals created in the App.
- We may also record which parts of the App users use and user patterns. This information will be kept securely in accordance with an internal security policy.
- We may disclose your personal information to Treat Partners and any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (both inside and outside of the European Economic Area):
- for marketing purposes; and
- to enable us to receive services which help us operate the App.
- We may also disclose and/or license your personal data that we obtain from the use of the App (and other data you submit through the app) to third parties:
- as part of the distribution or management of Treats which may be available through the App;
- to enable us to promote the App or particular Treats, and help us and those third parties understand how the App is used and Treats are sent, received and redeemed;
- in the event that we sell, transfer or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- if Givvit Limited or substantially all of its assets are acquired by or transferred to a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- with a view to preventing fraud or reducing credit risk.
- if we are obliged to do so to comply with law, regulations or a court order; if it’s necessary to enforce any of our terms and conditions or any other agreements to which we area party; if it is necessary to protect our rights, property or the safety of our customers or App users.
- We give you a choice of whether or not you want us or other companies to contact you about offers, events, products and services that may interested you.
- We might send you marketing emails about products or services which are similar to or related to the Website, or contact you by email with information about the Website. We will not send you any other marketing emails or pass your information on to third parties unless you give your consent or you have given it already.
- If you believe we have information about you that you do not want us to have or that is incorrect please contact us as described below and we shall correct or remove the data as you request as soon as is reasonably practicable.
- You also acknowledge and agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties, for example, in order to conform to any requirements of law, comply with any legal process, to prevent and detect fraud and to protect and defend our rights and property.
- The App may contain links to other websites or services of interest. However, once you have used these links to leave our App, you should note that we do not have any control over those third party sites or services. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question. Such sites and services have not been verified or reviewed by us and we have no liability for any use and access to them.
- For the purpose of the Data Protection Act 1998, the data controller is Startled Frog Limited with company number 07983137 whose registered office is at Unit 2A Vista Place, Coy Pond Business Park, Ingworth Road, Poole, Dorset, United Kingdom BH12 1JY.
- All questions, comments or enquiries should be directed by email to us at firstname.lastname@example.org