STICKLETS: Privacy Policy

"STICKLETS" iOS App: Privacy Policy

Introduction

We are Talking Places Limited, the developer of the "STICKLETS" app (the "App"), and we are committed to protecting your privacy and the integrity of your personal information. This Privacy Policy (“Policy”) explains how we collect and process your personal data when you use the App, your privacy rights, and how the law protects you.

This Policy describes:

what information we may collect about you
how we will use the information we collect about you
when we may use your details to contact you
whether we will disclose your details to anyone else
your choices regarding the personal information you provide to us

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such data, including the Data Protection Act 2018 and the European General Data Protection Regulation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 repealing Directive 95/46/EC, also known as the “GDPR” (these laws are referred to collectively in this Policy as the “data protection laws”).

Who We Are

This Policy is issued on behalf of Talking Places Limited ("we", "us", "our"), a company registered in England and Wales with company number 11609164 and whose registered address is Eden House, Reynolds Road, Beaconsfield, United Kingdom, HP9 2FL. For the purposes of the data protection laws, Talking Places Limited is the data controller and the entity responsible for the App.

Scope

This Policy applies to anybody who uses the App or who provides personal data via our website at https://www.openscreen.co/sticklets (our “Website”). It also applies to those who post material on the App, request communication via the App or our Website, and to personal data processed in pursuit of our own marketing and business development efforts. We may also ask you for personal data when you report a problem on our App.

The App is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.

Changes to this Policy

We reserve the right to amend this Policy from time to time. This version of the Policy was last updated on 17.05.2019. You will be informed of any material changes without delay.

We reserve the right, in the event that we buy or sell all or part of our business or assets, to disclose personal data held by us to the prospective seller or buyer of such business or assets.

Acknowledgement

The first time you submit data via the App, you will be asked to acknowledge and accept the practices described in this Policy. If you do not accept this Policy, you will not be able to post on, or view events or activities publicised via the App.

In addition, we will endeavour to bring this Policy to your attention every time we ask for your personal information and we will seek your specific consent whenever this is required.

Personal Data we collect from you

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 concerned has been removed. For the majority of events and activities posted on the App, it will not be necessary to disclose the identity of the individual posting that event or activity.

However, we will collect (and subsequently use, store and transfer) the following personal data about you:

your name, profile information and contact details when making an enquiry via the App or the Website, or when you otherwise voluntarily submit data to us;
technical data relating to your use of the App, such diagnostic and performance information, your App settings, log files, interactions with other users and information about your device;
device location information, for example when sharing information about the location of an event or activity, view locations nearby or those shared by other users, and for diagnostics and troubleshooting purposes;
your marketing preferences, which may be adjusted or withdrawn at any time;
information you provide when you complete surveys or enter competitions or enrol in promotional events;
information about your use of the App and our Website;
when you make a data subject access request.

It is not necessary to provide personal data to use the App and you are not obliged to provide your personal data to us at any time.

Processing Activities

We will only use your personal data to the extent required to fulfil a user’s instructions, or to improve the functionality of the app and our services to users, or when the law allows us to. The following table summarises the types of data processing activities we will undertake in relation to personal data subject to this Policy:

Information we Process	Purposes for Processing	Legal Basis for Processing
Publicly available information	To contact third parties to enquire whether they are interested in joining the App community.	Our legitimate interests, namely the pursuit of our own marketing and business development efforts.
Any personal data you provide to us on or after registration, such as names, contact details, trade, nature of activities undertaken, interests and preferences, posting history etc.	1. To facilitate the delivery of the services offered on the App by: establishing and maintaining contact between us and you; to facilitate the ability of others to provide you with information regarding events and activities reflecting your preferences and which we feel may interest you; to process and post your events, including the processing of any associated fees and charges; providing training and receiving feedback; any other requests you may have as a user of the App. 2. To deliver promotional materials when: specifically requested; consent is given by way of your marketing preferences; authorised in the context of a specific request. 3. To allow you to participate in competitions, prize draws, surveys or special features of the App, if you choose to do so; 4. To notify you about changes to our services and policies; 5. To publish reviews and testimonials; 6. To promote security and good practice on the App, to investigate suspicious activity or violation of our terms and conditions, and to ensure the App is being used for legitimate purposes.	1. The performance of our contractual obligations to you. 2. The performance of our contractual obligations to other users of the App. 3. Your consent, or our legitimate interests, specifically the pursuit of our own marketing and business development efforts. 4. Our legitimate interests, namely monitoring and improving the App’s performance and level of service to customers, and your consent whenever required.
Information you generate when you use the App	1. To ensure that content uploaded to the App is presented in the most effective manner for you and your device; 2. To administer and protect our business and the App, including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data; 3. To provide and/or enhance functionality on the App; 4. To analyse the performance of the App; 5. To use data analysis to improve our services and customer experience, marketing, customer relationships; 6. To deliver relevant marketing from time to time from us and our partners.	Our legitimate interests, namely monitoring and improving our Website and level of service to customers, and your consent whenever required.

Information we Process

Purposes for Processing

Legal Basis for Processing

Publicly available information

To contact third parties to enquire whether they are interested in joining the App community.

Our legitimate interests, namely the pursuit of our own marketing and business development efforts.

Any personal data you provide to us on or after registration, such as names, contact details, trade, nature of activities undertaken, interests and preferences, posting history etc.

1. To facilitate the delivery of the services offered on the App by:

establishing and maintaining contact between us and you;
to facilitate the ability of others to provide you with information regarding events and activities reflecting your preferences and which we feel may interest you;
to process and post your events, including the processing of any associated fees and charges;
providing training and receiving feedback;
any other requests you may have as a user of the App.

2. To deliver promotional materials when:

specifically requested;
consent is given by way of your marketing preferences;
authorised in the context of a specific request.

3. To allow you to participate in competitions, prize draws, surveys or special features of the App, if you choose to do so;

4. To notify you about changes to our services and policies;

5. To publish reviews and testimonials;

6. To promote security and good practice on the App, to investigate suspicious activity or violation of our terms and conditions, and to ensure the App is being used for legitimate purposes.

1. The performance of our contractual obligations to you.

2. The performance of our contractual obligations to other users of the App.

3. Your consent, or our legitimate interests, specifically the pursuit of our own marketing and business development efforts.

4. Our legitimate interests, namely monitoring and improving the App’s performance and level of service to customers, and your consent whenever required.

Information you generate when you use the App

1. To ensure that content uploaded to the App is presented in the most effective manner for you and your device;

2. To administer and protect our business and the App, including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data;

3. To provide and/or enhance functionality on the App;

4. To analyse the performance of the App;

5. To use data analysis to improve our services and customer experience, marketing, customer relationships;

6. To deliver relevant marketing from time to time from us and our partners.

Our legitimate interests, namely monitoring and improving our Website and level of service to customers, and your consent whenever required.

Marketing Preferences

You will only receive marketing communications from us if you have signed up for our newsletter or have requested marketing communications from us in the past.

We will ask for your express opt-in consent before we share your personal data with any third party for marketing purposes.

You may ask us to stop sending you marketing messages by clicking on the “Opt Out” link in our marketing messages. You may also opt out of marketing at any time by writing an email to stickets.support@openscreen.co.

Any opt out requests will not apply in respect of personal data provided to us for the purposes of fulfilling request to post an event or activity via the App.

Disclosure to Third Parties

You understand and acknowledge that we use third party service suppliers to facilitate business transacted via the App. These suppliers have given contractual undertakings that they will safeguard personal data disclosed to them in the course of providing such services in accordance with our instructions, and have agreed to be held liable in the event of any breach of data protection law for which they are responsible.

In addition to these suppliers, there are other third parties with whom we may need to share your personal information for the reasons set out below:

the right to be informed	the right to access	the right to rectification
Companies within our corporate group (including affiliates and ultimate beneficial owners), or who acquire a controlling interest in our business or its assets.	To facilitate the provision and promotion of our business and to monitor our business development.	The performance or negotiation of the contractual relationship between us and users of the App, and our legitimate interests, specifically the pursuit of our own marketing and business development efforts, and your consent whenever required by law.
Suppliers, such as payment merchants, software/IT systems, PR agencies and other third party service providers.	To facilitate the provision and promotion of events and activities publicised via the App, and to process payments associated with any services we provide via the App.	The performance or negotiation of the contractual relationship between us and our legitimate interests, specifically the pursuit of our own marketing and business development efforts.
Professional advisors, such as accountants and solicitors.	Only when necessary, and limited to what is necessary.	Our legitimate interests, namely the proper administration of our business, or fulfilling our legal obligations to users of the App or in relation to enforcing or defending legal claims.
Competent authorities, such as regulatory authorities, the Police and HMRC	Only when compelled to and/or when under an obligation to do so.	Compliance with legal obligations, such as for the purposes of fraud reporting or other criminal activity, or in order to apply or enforce our Terms of Use.

Your Data Subject Rights

We are committed to guaranteeing the statutory rights of individuals. If you send us a request regarding your rights under data protection law, we will respond within 30 calendar days of receipt and, where possible, address your request within such time. Where necessary, this period may be extended by up to a further 60 days.

The persons to whom this Policy applies are under no statutory or contractual obligation to provide personal data to us. However, should you decide to submit personal data to us, you will have the following rights, as a data subject, under data protection law as summarised below:

the right to be informed
the right to access
the right to rectification
the right to erasure
the right to restrict processing
the right to object to profiling
the right to data portability
the right to complain to the Information Commissioner's Office
the right to withdraw consent (e.g. to direct marketing)

Please note these rights may not always apply, for example if fulfilling your request would require us to reveal personal data relating to another user, or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest in keeping. If this is the case, then we will let you know at the same time as we respond to your request.

We do not engage in profiling which is capable of producing legal or other significant effects for individual data subjects.

Detailed information on the content and the means to exercise your rights is provided by the United Kingdom's Information Commissioner's Office, available here.

Retention Period

In respect of personal data within the scope of this Policy, we will retain such personal data until you advise us to securely dispose of it, or until it becomes outdated, or it is no longer appropriate for us to retain such data. It is your responsibility to inform us of any material changes to your personal data to ensure it is accurate. Outdated personal data will be periodically deleted in accordance with our internal data retention policies.

Security Measures

We have taken appropriate technical and organisational measures to ensure our own and our suppliers’ information security standards are appropriate to the risks associated with the personal data processing we undertake. Our security objectives include guaranteeing the confidentiality, integrity and availability of personal data and the resilience of the systems that process it. We have also 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.

It is your responsibility to keep the password provided to you on registration secure and confidential at all times. We will not be held liable for any breach of data protection law arising from your improper use of the App, or due to your password details being disclosed to any third party. In the event you have reason to believe your interactions with us are not secure, or the integrity of your login has been compromised, please contact us immediately.

International Transfers

We work solely with world-class suppliers, some of whom have branches outside the European Economic Area (‘EEA’). Any transfers of your personal data outside the EEA take place only subject to appropriate safeguards as provided in data protection law. These safeguards are intended to secure your rights as a data subject with respect to any relevant non-EEA domiciled entities.

Contact

In relation to any queries about this Policy or any other data protection matters, please email support.

May 2019

Talking Places Limited. Registered in England and Wales No. 11609164.

Registered Office: Eden House, Reynolds Road, Beaconsfield, Reynolds Road, Beaconsfield, United Kingdom, HP9 2FL