This policy was last updated on 10th September 2019
WHO COLLECTS THE DATA?
The data controller, who collects and manages the data, is Clarifi Media Ltd, Winnington House, 2 Woodberry Grove, North Finchley, London, N12 0DR
WHAT INFORMATION DO WE COLLECT FROM YOU?
We collect and process the following data about you:
1. INFORMATION YOU GIVE US DIRECTLY
You give us information about you by:
Providing us details via the app
You only need to give us your chosen display name and a predefined Safety Beacon message when you install the app. We don’t even collect or store your phone number. This very limited information is necessary to provide the contracted service to you.
Corresponding with us by phone, e-mail, online support request forms or otherwise.
We use the contact details and correspondence to respond to and deal with your request. It is necessary for our legitimate business purposes of handling the request and, in exceptional circumstances, investigations or defending or investigating legal issues.
If you sign up to our newsletter.
We use your email address if you choose to give it to us to sign up to our newsletter. We only do so with your consent, and you can of course choose to unsubscribe at any time via the link in the newsletter.
2. INFORMATION AN APP USER PROVIDES ABOUT YOU
If you are not a user of our app but are selected by an app user as a nominated Safety Beacon contact, we cannot identify you since emergency messages are activated through the user’s phone.
3. INFORMATION WE COLLECT ABOUT YOU
When you visit or use the app or our website, we may automatically collect the following information:
Information about usage of the app and website. This is through a Facebook pixel or Google Analytics and we use this information to better understand the use of our services and traffic to our app and website for the purposes of making improvements. We don’t use this data for advertising or to sell to other parties. We only collect this information with your consent. You can change your mind and deactivate these through your browser settings for computer based use and through your phone settings for apps. You can find out more about these technologies at www.allaboutcookies.com
Information about your location (only based on your consent). This will be your GPS-based location data used to help locate you as part of the Safety Beacon features but it is similar to a cookie and does not identify you personally. We only track you using your phone location for 60 minutes from activation. After that point we keep a record of your last location for 48 hours in case it is needed by you or emergency support and then it is deleted. You can enable or disable location services at any time through your mobile device settings.
INFORMATION ON CHILDREN
Our app is not directed to children under the age of 13.
Push notifications are updates that can automatically appear on your phone as an alert or pop up message following a particular event. For example, if you get a pop-up message when you get a new Facebook message, or your news app identifies a headline as ‘breaking news’, that is a push notification. We may send push notifications to your mobile device to provide relevant messages and app updates. We rely on consent to send push notifications so will only do so where you have agreed to receive them. You can always change your mind and manage push notifications from your device’s settings page for the relevant app.
WHO DO WE SHARE YOUR INFORMATION WITH?
The purpose of Safety Beacon is to notify chosen contacts in the event that you need help. Where you are an app user, we therefore share your message (and where you allow us, your location) only if requested and only with those you select.
Information may also be shared f we are under a duty to disclose or share personal data in order to comply with any legal obligation or to defend our rights. Information may also be provided to a third party if we or substantially all of our assets are acquired by that third party.
HOW AND WHERE DO WE STORE YOUR DATA?
We store data in Ireland. In the event of a Brexit, where required, we ensure that appropriate contractual safeguards are in place to enable the transfer of personal data out of the European Economic Area. Further details are available on request.
All information you provide to us is stored on our secure servers. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR DATA?
In certain circumstances, you have rights under data protection laws in relation to the personal data we hold about you. You can request the following but please note that these are not absolute rights and therefore may be subject to exemptions and exceptions depending on the circumstances:
- access information held about you;
- rectify any incorrect or incomplete data we hold about you;
- delete, restrict or remove the data we hold about you;
- transfer the data we hold about you to another party;
- object to further processing of your data.
We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
- refuse your request based on the exemptions set out in the applicable data protection laws;
- request for proof of your ID to process the request or request further information;
- charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with our regulator, the Information Commissioner’s Office (ICO). Please see the ICO website for further details, www.ico.org.uk.
HOW LONG DO YOU KEEP MY DATA?
We keep your data for as long as it is necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements. To determine the appropriate length of time for holding your 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 purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements. Details of how long we keep location data is explained above but is no longer than 48 hours.
This policy was last updated on the 10th September 2019