This Policy provides information on how we collect and process your personal data when you access or sign up to our application known as “Squaddy”, visit our website or otherwise purchase a product or service through Squaddy. Collectively, Squaddy and any website relating to that application will be referred to as (“Platform”) in this Policy.
1. Important Information and Who We Are
Full name of legal entity: Projektt Technologies Ltd
Email address: email@example.com
Postal address: 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ
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.
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.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data including name, username or similar identifier, date of birth, email address and gender.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Platform, products and services.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
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 a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity by creating a user account or by corresponding with us. This includes personal data you provide when you:
- apply for our products or services;
- create an account;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will receive personal data about you from various third parties including Profile Data from Google Authenticator and payment services such as Stripe, Apple Store or Android.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- To improve our products and services including the Platform.
- 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data unless required by law.
5. Purposes for which we will use your personal data
We will only use your personal data for the purpose for which we collected it which include the following:
- To register you as a new user.
- To process and deliver your order or purchase.
- To manage your relationship with us.
- To enable you to participate in a prize draw, competition or complete a survey.
- To improve our website, products/services, marketing or customer relationships.
- To recommend products or services which may be of interest to you.
6. Disclosure of your personal data
We may share your personal data with the following parties:
- Trainers to enable your use and ability to benefit from the Platform; or
- Government authorities when required by law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Data retention
How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
For the avoidance of doubt, if your account is deleted we will retain your data for a maximum of 6 years. If your account is light-inactive for a continuous period of 18 months, it will be deleted and its associated data will be retained for a maximum of 6 years from the account deletion date. For any videos uploaded on the “Feed” page on the Platform, we will delete or retain such videos depending on the activity (or lack thereof) they attract. We may delete some videos after 30 days if, e.g., they generate no activity on the Platform.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you, the right to request deletion of your data and the right to make a complaint at any time to the Information Commissioner's Office, the UK supervisory authority for data protection issues (www.ico.org.uk). If you’d like to contact us regarding these rights or otherwise concerning this policy, please contact us including by email on firstname.lastname@example.org