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Introduction
This policy together with the App User Terms and any additional terms of use incorporated by reference into the App User Terms applies to your use of:
the Quotake application software (“App”), (available on a number on different App marketplaces, including Google Play and Apple App Store) (the “App Sites”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”); and
any of the services accessible through the App (“Service”) that are available on the App or other sites of ours (“Services Sites”) unless this policy or the App User Terms states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
Important information and who we are
Quotake Limited is the controller and is responsible for your personal data (collectively referred to as “Quotake”, “we”, “us” or “our” in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Quotake Limited
Email address: [email protected]
Postal address: 71–75 Shelton Street, Covent Garden, London, 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.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed.
This policy applies to any person using the App (“User”) or the Services Sites.
The App is not intended for anyone under the age of 16 unless you have verifiable consent from a parent or guardian.
For the avoidance of doubt, by registering, or using, or supplying data or information through the App or the Services Sites, you are aware of the collection, use and transfer of that data and your information under the terms of this privacy policy.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 17 October 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email within 30 days once a change has been made to let you know of the change and the reason for it. You do not need to do anything and continued use of the App and Services will be deemed as your agreement to the changes. If you do not accept the notified changes you will not be permitted to continue to use the App and the Services. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
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 our relationship with you.
Third party links
Our Services Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data collected about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
Identity Data including your first name, last name, date of birth, and your username or similar identifier.
Contact Data includes your home or business address, email address and telephone number.
Financial Data includes your bank account and payment card details.
Transaction Data includes details about payments to and from you and details of in-App purchases.
Device Data includes the type of mobile device you use, your mobile operating system and device name.
Content Data includes information stored on your Device, including friends’ lists, login information, book data, notes, quote data, photos, videos or other digital content.
Profile Data includes your username and hash for a password, in-App purchase history, your interests, preferences, feedback and survey responses and profile picture.
Usage Data including details of your use of any our Apps, products or Services or your visits to any of Our Sites.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data includes your current location disclosed by GPS technology.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
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.
Unless specified otherwise, all personal data requested by us is mandatory and failure to provide this may make it impossible for us to provide the Services. In cases where we specifically state that some personal data is not mandatory, you are free not to communicate this personal data without consequences to the availability or the functioning of the Service.
You are responsible for any third-party personal data obtained, published or shared through the Service or Services Sites and confirm that you have the third party’s consent to provide the personal data to us.
How is your personal data collected?
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, make an In-App purchase, search for an App or Service, enter a competition, promotion or survey and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
We also collect data from parents who register and create profiles for children under the age of 16, when parents sign up for marketing emails.
Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
Device Data from the following parties:
analytics providers such as Google based inside and outside the UK;
advertising networks based inside and outside the UK;
facebook, Twitter, Google and Apple login; and
search information providers such as Google based inside and outside the UK.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services inside and outside the UK; and
Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
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 or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We may carry out limited marketing which parents (children under the age of 16) may sign up for.
Purposes for which we will use your personal data
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table “Purposes for which we will use your personal data”:
External Third Parties as set out in the Glossary.
Specific third parties listed in the table Purposes for which we will use your personal data.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We may disclose your personal information to third parties:
If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
To a contractor appointed by us to deliver elements of the App or the Services on our behalf;
For administration of your Quotake App account;
Other trusted third parties, who will receive it as data controllers in their own right (such as auditors, consultants and legal advisers). In such cases, we will ensure that the appropriate contracts and safeguards are in place;
Third party processors for Our Site and App analytics purposes;
In order to comply with our legal, regulatory and statutory obligations, sometimes we also need to pass your personal information to third parties, such as courts, law enforcement agencies, our insurers, our auditors, and our professional advisers;
In order to enforce or apply the App Terms of Use or to investigate potential breaches of the same and/or protect the rights, property or safety of us, or our respective customers;
Location of processing and international transfers
Quotake is incorporated in the United Kingdom. Information collected via our Services or Services Sites may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data.
The personal data is processed at Microsoft Azure in the United Kingdom and in any other places where the parties involved in the processing are located.
Depending on your location, data transfers may involve transferring your personal data to a country other than your own.
We are allowed to transfer personal data collected within the UK to third countries only subject to specific legal requirements (known as “restricted transfers”). Restricted transfers may take place according to the conditions specified below.
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts (standard contractual clauses) approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where we have given you (or where you have chosen) a password that 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.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on a local database, which is installed with part of the App and is only accessible by the App code and App Stores based operational information.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Data retention
We will retain a record of your personal data in accordance with relevant law and the following criteria:
Where we have a reasonable business need to do so, for example, in order to manage our relationship with you;
Where we are providing products and/or services to you and then for as long as someone could bring a claim against us in respect of those products or services; and/or
In line with any legal and regulatory requirements or guidance in respect of retention periods.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
External third parties
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Payment processors we work with including Apple Store In-App Payments and Google Pay In-App Payments.
Your legal rights
You have a number of important legal rights regarding the manner in which the personal data relating to you is used.
We have outlined below the key rights which we believe may be relevant to your use of the App and/or the Services.
If you would like to exercise any of these rights then please contact us using the information in the section headed ‘Important information and who we are” above. Please note that you may be asked to provide us with reasonable proof of your identity so that we can be sure that we are discussing or providing your personal data with, or to, you (or if someone is making a request on your behalf, we need to check that they have the authority to do so).
Request access to your personal data (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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.