Privacy Policy

 

1.      Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and app users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and/or app users - in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website. Please see our Cookie Policy for more information on cookies, including how we use them and your rights in relation to them.

1.4    Our apps incorporate privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via Privacy Settings.

1.5    In this policy:

 “our apps” means the Squad Social apps available from the Apple Appstore and/or Google Play from time to time; and “we”, “us” and “our” refer to Squad Systems Limited. For more information about us, please see Section 13 below.

2.      How we use your personal data

2.1    In this Section 2 we set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and our apps ("usage data"). Usage data may include your IP address, geographical location, browser type and version (in the case of our website), operating system, referral source (in the case of our website), length of visit/use, page views, and website or app navigation paths, as well as information about the timing, frequency and pattern of you use of our website and our apps. The source of usage data is Google Analytics – please see our Cookie Policy  for more details. Google Analytics data may be processed for the purposes of analysing the use of, and improving, the website. Other usage data may be processed for the purposes of analysing the use of, and improving, our apps, and maintaining back-ups of our databases. The legal basis for processing usage data is our legitimate interests, namely monitoring and improving our website and our apps.

2.3    We may process your account data ("account data"). Account data may include your name, telephone number, email address, and date of birth. The source of account data is you. Account data may be processed for the purposes of operating our apps, providing services via our apps, ensuring the security of our apps and services, communicating with you, and maintaining back-ups of our databases. The legal basis for processing account data is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4    We may process your information included in your personal profile on our apps ("profile data"). Profile data may include your name, profile pictures, gender identity, sexuality, date of birth, relationship status, interests and hobbies, educational details, and employment details. The source of profile data is you. Profile data may be processed for the purposes of enabling and monitoring your use of our services via our apps and maintaining back-ups of our databases, including by sharing profile data with and making profile data available to other users of the apps and using profile data to suggest groups and activities you may be interested in participating in. The legal basis for processing your gender identity and sexuality is consent. The legal basis for processing all other profile data is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

2.5    We may process your personal data that are provided in the course of the use of our apps and services ("service data"). Service data may include (but not be limited to) joining a community, capturing interactions with content, marking that you are attending an event. The source of service data is you. Service data may be processed for the purposes of operating our apps, providing services via our apps, ensuring the security of our apps and services, communicating with you, and maintaining back-ups of our databases. The legal basis for processing service data is the performance of a contract between you and us.

2.6    We may process information that you post for publication via our apps ("publication data"). Publication data may be processed for the purposes of enabling such publication, administering our apps and services, and maintaining back-ups of our databases. The legal basis for processing publication data is the performance of a contract between you and us.

2.7    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). Enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you, and maintaining back-ups of our databases. The legal basis for processing enquiry data is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

2.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). Notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and maintaining back-ups of our databases. The legal basis for processing notification data is consent.

2.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). Correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you, record-keeping, and maintaining back-ups of our databases. The legal basis for processing correspondence data is our legitimate interests, namely the proper administration of our website, apps, and business, and communications with users and others.

2.10  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings, arbitration, mediation or other form of alternative dispute resolution. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

2.12  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.14  Please do not supply any other person's personal data to us, unless we prompt you to do so.

3.      Automated decision-making

        We will not use your personal data for the purposes of automated decision-making, including profiling,     which produces legal effects concerning you or similarly significantly affects you.

4.      Providing your personal data to others

4.1    If we are a member of a group of companies from time to time, we may disclose your personal data to any member of our group (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings, arbitration, mediation or other form of alternative dispute resolution.

4.3    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary:

(a)    for compliance with a legal obligation to which we are subject;

(b)    in order to protect your vital interests or the vital interests of another natural person;

(c)    for the establishment, exercise or defence of legal claims, whether in court proceedings, arbitration, mediation or other form of alternative dispute resolution; or

(d)    the investigation of any alleged breach of our Terms of Service, fraud or attempted fraud in relation to our utilising our apps.

5.      International transfers of your personal data

       

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    Our app developers have offices situated in India. Transfers to our app developers will be for diagnostic purposes and to enable them to provide customer service services for us. Transfers  will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

5.3    You acknowledge that personal data that you submit for publication through our apps may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6.      Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes will not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will usually retain your personal data as follows:

(a)    usage data will be retained for a maximum period of two years;

(b)    account data will be retained until you cancel your account or it is terminated by us;

(c)    profile data consisting of gender identity or sexual orientation will be retained until you withdraw your consent to us processing them or you cancel your account or it is terminated by us, whichever is earlier;

(d)    profile data not specified in (c) above will be retained until you cancel your account or it is terminated by us;

(e)    service data will be retained until you cancel your account or until such earlier time (if any) as they are no longer necessary for the purpose or purposes for which they were provided;

(f)    publication data will be retained until you cancel your account or it is terminated by us;

(g)    enquiry data which does not lead to a contract between you and us will be retained for one year from the date negotiations cease;

(h)    enquiry date which does lead to a contract between us will be retained for six years from the date of termination of that contract;

(i)    notification data will be retained until you withdraw your consent;

(j)    correspondence data will be retained for six years from the date of the last item of correspondence in a particular chain.

6.4    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary:

(a)    for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person; or

(b)    to enable us to investigate, and if appropriate take action in relation to, any complaint against you by another user of our apps or any alleged breach of our Terms of Service.

6.5    You can cancel your account at any time by using Account Settings in our apps. If you cancel your account, we will delete everything that you have posted using our apps. You will not be able to access or recover any of this data once it has been deleted. Information about you that other users of our apps have posted will not be deleted until such time, if ever, as those other users request its deletion or close their accounts or we terminate their accounts.

6.6    Please note that although we will initiate the process of deleting your data as set out in Section 6.3, copies of your data may exist in our back-up databases until such time as they are over-written in the ordinary course of our scheduled back-ups.

7.      Amendments

7.1    We may update or replace this policy from time to time as and when we consider it appropriate to do so by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email or through the private messaging system or other mechanisms on our apps.

8.      Your rights

8.1    In this Section 8, we summarise the rights that you have under data protection law in the United Kingdom. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

8.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only then process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9    You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

(c)     and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. You can go to https://edpb.europa.eu/about-edpb/board/members_en for a list of local data protection authorities in the EEA countries.

8.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13  You may exercise any of your rights in relation to your personal data by written or email notice to us using the contact details in Section 12 below.

9.      Third party websites

9.1    Our website includes hyperlinks to, and details of, third party websites.

9.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.    Personal data of children

10.1  Our apps and services are targeted at, and only available to, persons who are aged 18 or older.

10.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.    Updating your information

        Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.    Our details

12.1  This website is owned and operated by Squad Systems Limited as are our apps.

12.2  We are registered in England and Wales under registration number 11500034, and our registered office is at Flat 4, 111 Gosset Street, London E2 6NP.

12.3  Our principal place of business is at Flat 4, 111 Gosset Street, London, England, E2 6NP.

12.4  You can contact us:

(a)    via the contact us page on our apps;

(b)    by email, using support@squad.social;

(c)    by post, to Squad Systems Limited, 111 Gosset Street London E2 6NP.

 

 

Last revised: 10 January 2019

 

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