The Data Controller is responsible for determining the processing purposes of your personal data, and the content and related services or features which are made available to you from using this Service.
2. Where do we collect personal data about you from?
We may collect personal data about you from the following sources:
Directly from you. This is information you have voluntarily provided whilst entering your personal details on the Service.
We do not collect personal data about you from any agent/third party acting on your behalf.
3. What Information Do We Collect and Why?
We will only ever collect the information We need to enable us to undertake the specific information processing activities noted later in this section.
We collect and process two distinct kinds of information:
- Non-personal information such as the pages you have accessed, helping Us to determine how many people use Our Service, how many people visit on a regular basis, and how popular each of Our pages are. This information doesn't tell Us anything about who you are or where you live. It simply allows Us to monitor and improve Our service.
- Personal information such as your IP address, email address, username, password, approximate location and any optional information you may choose to provide to Us as part of your experience within the Service (e.g. text, photograph).
Should you decide to register we ask for the following information:
- Email address – we use this to send you a welcome email, and any service related communications such as resetting your password or verifying your email address. We will not send you any marketing or third-party messages unless you have explicitly provided your consent for Us to do so.
- Your name/username – we ask for a username so that if you make any posts or comments that these are attributable to you. Other users will also be able to search for you by name, and it will be shown on your public profile page. You do not need to use your real name, though we generally encourage it.
- A photo – this is required and will be shown next to any posts and comments you make, as well as on your public profile page.
- A password – we store this in a secure one-way encrypted system. If you forget your password, you may request that it be reset, and we will send an email to you with instructions on how to do so.
Once registration is complete, and you have verified your email you may, if you choose, post, and comment in the App. Please bear in mind that any posts and comments you make on some forms of content (e.g. articles, or “Insights”) may be viewed by non-registered users in the App on public web pages.
As you use the App We will keep track of what sections you have visited, so that We can highlight sections or content to you that you may have missed. We also use this data in an aggregated form to understand how popular the App and its different sections are so that We can improve the service. This data is never shared with anyone and is only used for Our internal purposes.
We record the last IP address you accessed the service from so that We can protect the service from malicious access. As part of this We may look up the approximate location of the IP address such as country and city.
Your decision to disclose your personal information to Us is entirely voluntary. If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, you may not be able to access or use the App.
We will only retain your personal information for as long as you are a registered user of the App. We comply with all legislative and regulatory information retention requirements and will securely and permanently delete your personal information when there is (a) no justification for its further retention, or (b) you have asked Us to delete it.
5. Children’s Personal Data
This Service, and any services available from it, are not directed to users under the age of 16. If you learn that a user under the age of 16 has provided Us with their personal information without having parental or guardian consent, please contact Us (see Section 11) immediately so we can take appropriate action.
6. User Data Rights
If you are based in the EU, under the General Data Protection Regulation you have several rights connected to the provision of your personal information to Us from using the Service:
1. The right to be informed
2. The right of access
You have the right to obtain access to your personal information (if We’re processing it), and certain other information such as the reasons why we are processing or storing it. This is so you’re aware and can check that We’re using your personal information in accordance with data protection legislation and your agreement.
3. The right to rectification
You are entitled to request that your personal information is promptly corrected if it’s identified as being inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information under certain circumstances where there’s no compelling reason for Us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your personal information. When processing is restricted We can still store your information but may not be able to process it further. We maintain lists of people who have asked for further use of their personal information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between Our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing
You have the right to object to certain types of personal data processing, including processing for direct marketing activities.
8. The right to lodge a complaint
You have the right to lodge a complaint about the way We have handled or processed your personal data with your national data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything We do with your personal data, you have the right to vary or withdraw your consent at any time (although if you do so, it does not mean that anything We have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw your consent to Us using your personal data for marketing purposes.
We usually act on validated requests and provide the requested information or activity free of charge, but by law we are allowed to charge a reasonable fee to cover Our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, there are reasons why We may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as We can. Generally, this will be within one month from when We receive your validated request but, if the request is going to take longer to deal with, We will let you know.
To contact Us please see Section 11 below. If We do not address your request or fail to provide you with a valid reason why We are unable to do so, you have the right to contact your national data protection regulator.
7. International Transfers of Personal Data
As We have described above, to be able to provide you with the Services We may transfer your personal data to partners in different countries. These countries’ privacy laws may be different from those in your home country.
Should We transfer data to a country which has not been deemed to provide adequate data protection standards We always have security measures and approved model clauses in place to protect your personal data.
If you are based in the EU, by voluntarily submitting your personal data to us you consent to these international transfer. If you later wish to withdraw your consent, please contact the Data Controller using the details in Section 11.
Cookies are small text files sent by websites to your web browser and sent back to them each time you access or use the site, and may be necessary for the site to function. They are unique to you or your web browser and may contain personally identifiable information as well as technical information (e.g. your device manufacturer and model, screen resolution, internet service provider, browser, and geo-location data). Session-based cookies last only while your browser is open and are automatically deleted when you close the browser. Persistent cookies last until you or your browser delete them, or until they expire.
9. External Links
The Service includes relevant hyperlinks (posted by us or App users) to external websites which are not directly controlled by Us. Whilst all reasonable care has been exercised in selecting and providing such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do we continually verify the safety or security of the contents which may be provided to you. You are advised, therefore, that your use of external links is at your own risk and We cannot be responsible for any damages or consequences caused by your use of them.
11. Contacting the Data Controller