Our full details are: Full name of legal entity: Goog Ltd Email address: firstname.lastname@example.org Postal address: 12 Constance Street, London. E16 2DQ. If you are not happy with any aspect of how we collect and use your data when using our App, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
2. WHAT DATA DO WE COLLECT ABOUT YOU?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
• Identity Data may include your first name, last name, title, date of birth, relationship to child and gender. This is collected during the onboarding process when you first download our App.
• Contact Data may include your address, email address and telephone numbers. During the onboarding process you have the option to provide us with your address so that we can send you samples and or offers in the post.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access the App.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our App, products and services and clicks to third party sites.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of App users using a specific feature of our App. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data and will be looked after in accordance with this privacy notice.
Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences. We do ask for a users pregnancy due date. As this reveals information about a person’s health it is classified as sensitive data. We ask for a users due date in order to be able to feed a user the most useful information at the right time in their pregnancy journey. This is optional and if it is not disclosed the App will presume you are in your first week of pregnancy and will feed you information as if you are due in 40 weeks.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (eg a winner of a competition). If you don’t provide us with the requested data, we may have to cancel a prize but if we do, we will notify you at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
• Direct interactions: You may provide data by filling in our onboarding form when you initially download the bumpf App or by communicating with us by post, phone, email or otherwise, including when you:
o create an account on our App;
o subscribe to our service or publications;
o request resources or marketing be sent to you;
o enter a competition, prize draw, promotion or survey; or
o give us feedback.
• Automated technologies or interactions: As you use our App, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using server logs and similar technologies.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
• Where we need to perform the contract between us.
• 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 or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org or my changing your preferences at any time within the App. Click on account settings (little cog on the top right of the screen). Navigate to My Preferences. In this area you can opt in or out of receiving emails or items in the post.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity: To register you as a new user of the App
Type of data: (a) Identity (b) Contact
Lawful basis for processing: Performance of a contract with you. We ask for date of birth to ensure all users are over 18.
Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our App.
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our App, to develop and grow our business
Purpose/Activity: To administer and protect our business and our App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: a) Identity (b) Contact (c) Technical
Lawful basis for processing: (a) Necessary for our legitimate interests for running our business, provision of administration and IT 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 content and advertisements to you and measure and understand the effectiveness of our advertising
Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing: Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
Purpose/Activity: To use data analytics to improve our App, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical (b) Usage
Lawful basis for processing: Necessary for our legitimate interests to define types of customers for our products and services, to keep our App updated and relevant, to develop our business 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
Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
Lawful basis for processing: Necessary for our legitimate interests to develop our products/services and grow our business
Purpose/Activity: To feed you relevant articles, offers, diary prompts and shopping list ideas when using our App. To enable you to benefit from the App and personalise your own journey.
Type of data: (a) Identity incl sensitive (b) Contact (c) Technical (d) Usage (e) Profile
Lawful basis for processing: Necessary for our legitimate interests to develop our products/services and grow our business and perform the full functions of the App.
You will receive marketing communications from us if you have:
(i) requested information from us or
(ii) if you provided us with your details when you entered a competition or registered for a promotion or free resources or
(iii) opted in to receiving emails and or information in the post when signing up to our App; and
(iv) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party 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 (within the account settings area of the App) OR by following the opt-out links on any marketing message sent to you OR by emailing us at firstname.lastname@example.org at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
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 such data. 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.
8. DATA RETENTION
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise 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. These include the right to:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at email@example.com.
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.
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 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.
10. THIRD-PARTY LINKS
Our App includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy notice of every website you visit.
If you have any questions at all about how we store and use your data please do email us. We love to hear from our users and will endeavour to respond as speedily as possible. firstname.lastname@example.org