Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We are Whereverly Limited. We are a company incorporated and registered in Scotland. Our company number is SC542009. Our registered office address is 2 Walker Street, Edinburgh, EH3 7LB.
When we refer to “we”, “us” or ”our” in this policy, we are referring to Whereverly Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.
We use the following definitions in this policy to cover the different categories of individuals that this policy applies to:
Our Sites may include 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 Sites, we encourage you to read the privacy notice of every website you visit.
We use different methods to collect data from and about you including through:
We may collect and process the following data about you:
If you have 'Background Location Data' turned on, from time to time, the App will collect location data when the App is in the background even if you are not directly interacting with the App. The App does this to enable location based features such as location based badge unlocking. We do not share background location data with any parties, the background location data remains on the device.
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:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that 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 Contact us 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||Type of data||Lawful basis for processing|
|To respond to your enquiries||Contact Data||Consent (as you are requesting us to respond to you). Necessary for our legitimate interests (to respond to enquiries from Customers and potential customers|
|To enable Registered Users to access the Services||Account Data||Performance of a contract with you|
|To enable End Users to use the App||Account Data Location Data||Performance of a contract with you|
|To send you marketing emails||Marketing Data||Consent Legitimate interests (to market to network of Customers and contacts)|
|To personalise our Sites and improve user experience in relation to the Sites, the Apps and Services||Device Data Technical Data Usage Data Location Data||Legitimate interests (to improve customer interactions)|
|To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Contact Data Technical Data||Necessary for our legitimate interests (for running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Performance of a contract with you|
|To analyse and create anonymised data on End User use and interaction which we may share with Customers Device Data||Usage Data Location Data||Necessary for our legitimate interests (to understand and improve End User interaction, to develop analytical data for Customer use)|
We may have to share your personal information with the following third parties:
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.
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.
|Service provider||Description of service||Safeguards|
|Google Forms||Customer feedback and survey||Privacy Shield|
|EventBrite||Marketing - event management||Privacy Shield|
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures in accordance with industry best practice 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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
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.
We normally delete personal identifiable information we hold on you within 10 years but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.
Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.
A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.
The cookies that we use fall into the following categories:
We use various types of cookies (including some that we place and others which we permit third parties to place on our Sites) for a number of purposes. The information collected by cookies allows us to monitor how many people are using our services and their interactions with other services. Cookies are also used to facilitate a user's log-in, as navigation aids, and as session timers.
If for any reason you do not want us to track your use of our Sites using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser).
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
To find out how to manage cookies on popular browsers:
To opt out of being tracked by Google Analytics across our Sites, visit http://tools.google.com/dlpage/gaoptout.
We use web beacons to collect information about the use of our services. The information collected by web beacons allows us to monitor how many people are using our services, how many people open our e-mails, and determine for what purposes these actions are being taken. Our web beacons are not used to track activity outside of our services.
Before cookies are placed on your computer or device, you will receive a pop-up prompt requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our Sites may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Google Analytics||3rd Party||Analytics||https://support.google.com/analytics/answer/6004245|
|Add To Any||3rd Party||Social Sharing||https://www.addtoany.com/privacy|
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out below, please Contact us. 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.
You have the right to ask for a copy of the information which we hold on you (commonly known as a ‘data subject access request’).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
You have the right to request that we correct personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold corrected, though we may need to verify the accuracy of the new data that you provide to us.
You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your informat or where we are required to erase your personal data to comply with local law.
Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
You may also object to us processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
In certain circumstances, you may request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do Contact us in the first instance if possible.
This version was last updated on 22nd June 2018
Historic version of this policy can be obtained by Contacting us.
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.
Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Privacy Manager at firstname.lastname@example.org.