As of June 2019
1.4 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.
2.1 Our company name is Toucan App Limited, a UK Limited company registered in England under company number 11514165 with our registered office at 28 Ely Place, London EC1N 6TD, United Kingdom.
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.2.1 Identity Data - first name, last name, username or similar identifier. When you email, phone, live chat, participate in interviews or otherwise, we may collect information such as your first name, last name, email address and phone number.
3.2.2 Contact Data - email address and telephone numbers.
3.2.3 Financial and Transaction Data – bank account, card details and details of your transactions, payments and banking.
3.2.4 Technical Data - 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 Site.
3.2.5 Profile Data includes your username and password, your interests, preferences, feedback and interview and survey responses.
3.2.6 Usage Data includes information about how you use our Site and services.
3.2.7 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.2.8 Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Site. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, academic researchers and search information providers) and may receive information about you from them.
3.4 Where we do collect sensitive personal data about you (this may include details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and it is necessary to do so for the purposes in section 4.2 below, we will obtain your specific consent, unless we have another lawful basis to do so.
3.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
3.5.1 You have given consent to the processing of your personal data for one or more specific purposes;
3.5.2 processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
3.5.3 processing is necessary for compliance with a legal obligation to which we are subject;
3.5.4 Details of your visits to our Site and the resources you use;
3.5.5 Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers;
3.5.6 processing is necessary to protect the vital interests of you or of another natural person;
3.5.7 processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
3.5.8 processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
4.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through direct interactions. You may give us your information by filling in forms via our Site, during interviews or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you view Site content, use any of our Site services, create an account on our Site, request marketing to be sent to you, participate in interviews or give us some feedback.
4.2 In addition to the above, we may use the information in the following ways:
4.2.1 To personalise your Site experience and to allow us to deliver the type of content and product offerings in which you are most interested;
4.2.2 Present Site content and the relevant services effectively to you;
4.2.3 Provide information, and services that you request, or (with your consent) which we think may interest you;
4.2.4 Carry out our contracts with you;
4.2.5 Carry out our research on financial delegation/third party access; and
4.2.6 Tell you our charges.
4.3 If you don't want us to use your personal data for any of the other reasons set out in this section 4, you can let us know at any time by contacting us at email@example.com, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide you further access to the Site and its services.
4.4 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don't provide your personal data in these cases.
4.5 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:
4.5.1 Where we need to perform the contract we are about to enter into or have entered into with you;
4.5.2 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; or
4.5.3 Where we need to comply with a legal or regulatory obligation
5.2 Cookies are small text files placed on your device when you visit our Site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the Site however, for non-essential cookies we need your permission.
5.4 All our cookies are categorised by the role they fulfil on our Site:
5.4.1 Strictly Necessary: these are essential to enable you to move around our Site and use features such as secure services. Without these cookies such services could not be provided;
5.4.2 Functionality: allow the Site to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
5.4.3 Performance: collect information as to how users use the Site. These cookies don't collect information that identifies a visitor. The information collected is aggregated and used to improve our website.
5.5 If at any time you wish to disable our cookies, you may do so through the settings on your browser. However, if you choose to disable or delete our cookies that will prevent certain important areas and features of our service from functioning properly.
6.1 We store your collected data within the European Economic Area (EEA). Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Site. 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.
6.2 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. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
6.3 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.
6.4 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
6.5 If we give you a password upon registration on our Site, you must keep it confidential. Please don't share it.
6.6 We will keep personal data for as long as is necessary which is usually the life of our relationship and up to a period of seven years after our relationship have ended. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
7.1 We are allowed to disclose your information in the following cases:
7.1.1 If we want to sell our business, or our company, we can disclose it to the potential buyer;
7.1.2 We can disclose it to other businesses in our group;
7.1.3 We can disclose it if we have a legal obligation to do so, or in order to protect your or other people's property, safety or rights; and/or
7.1.4 We can exchange information with others to protect against fraud or credit risks.
7.2 We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8.2 Under GDPR, you have the right to:
8.2.1 request access to, deletion of or correction of, your personal data held by us at no cost to you;
8.2.2 request that your personal data be transferred to another person (data portability);
8.2.3 be informed of what data processing is taking place;
8.2.4 restrict processing;
8.2.5 object to processing of your personal data; and
8.2.6 complain to a supervisory authority.
8.3 You have the right to ask us not to process your personal data for marketing purposes. We will always inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
9.2 The English courts have the only right to hear claims related to our Site, and all disputes are governed by English law.
10.1 Please email us at firstname.lastname@example.org to contact us about any issues.