Last updated: March 29th, 2019
Maldaba Limited with company no. 05187518, registered address at Gates Freedman & Co, 2nd Floor Sutherland House, 70-78 West Hendon Broadway, London, NW9 7ER, trading address 3rd Floor, 125 Charing Cross Road, London WC2H 0EW and VAT no. 940 2303 66 (“us”, “our”, “we”, “Maldaba”) are committed to protecting and respecting your privacy.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 the Data Controller of your Personal Data in the Service is Maldaba.
1. LEGAL INFORMATION
Please read this policy in conjunction with the EULA. Any capitalised terms used but not defined in this policy shall have the meanings given to them in the EULA.
- Legal Information
- What is personal data and what do we collect
- How and why do we use/share your information
- For how long do we keep your information
- Security & International Data Transfers
- Your Rights
- Contact Details
Please note that our Service is not directed at children under the age of 13 (each “Child” together “Children”) and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child without parental consent, you may contact us at email@example.com and request that we cease processing information about your Child.
3. What is Personal Data and what do we collect?
What is personal data?
Data we collect from you when you use our Service
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you use the Service to upload or send personal data (by recording important health information such as symptoms, recording meetings with health care providers, uploading photos and videos to provide carers with instructions, messaging shared users, participating in user forums, by subscribing to our newsletter or similar activities in which you volunteer data about yourself) contact us by post, telephone, email or SMS; report a problem with a Service; we may collect, store and use the personal data that you disclose to us.
We only collect, store and process Identity and Contact Data from you (such as your title, name, address, e-mail address, company name and phone number). You may use our service to input and share your Personal Data (as stipulated above) including Special Categories of Personal Data. This may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, health information and genetic and biometric data. We do not process these Special Categories of Personal Data.
The types of data we collect will depend on precisely what details you volunteer to us when you interact with the Service.
Automated Collection of Data
- information about your device, browser or operating systems;
- your mobile device unique ID;
- your computer’s IP address;
- information about links that you click and pages you view on our Service
- length of visits to certain pages;
- subjects you viewed or searched for;
- page response times;
- records of download errors and/or broken links;
- page interaction information (such as details of your scrolling, clicks, and mouse-overs);
- methods used to browse away from the page; and
- the full Uniform Resource Locators (URL) clickstream to, through and from this Service (including date and time).
We use the data described above for several different reasons. Firstly we use it to ensure that the Service works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Service. We undertake both of these activities because we have a legitimate interest in doing so.
Third Party Resources
We also use the services of third parties to help us to collect various data about you and the way that you use the Service in order to enable us to better understand your interests – both so that we can service content to you that we think will be of interest to you, and so that we can ensure that you are shown adverts delivered by third parties which are more likely to be of interest to you.
Third parties that help us to better understand your use of our Service include:
- Google Inc.’s Google Analytics service – for more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout
For further details of the cookies that we use on the Service and what those cookies do, please see our Cookies Policy.
4. How and why do we use/share your information
Sharing your information
Depending on how and why you provide us with your personal data we may share it in the following ways:
- we may share your personal information with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- with selected third parties who we sub-contract to provide various services and/or aspects of the Service’s functionality (see “Service Providers” below); and
- with analytics and search engine providers that assist us in the improvement and optimisation of this Service as described above.
We will not share your information with third parties in order for that third party to provide direct marketing communications to you.
We may also disclose your personal information to third parties in the following events:
- if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets as part of that sale;
- if Maldaba or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:
Links to third party sites
5. For how long do we keep your information?
We will hold your personal information on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive e-mail marketing from us (such as newsletters) we will retain your e-mail address on file should you ever ‘opt-out’ of receiving e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
In some circumstances we may 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.
6. Security & International Data Transfers
Maldaba takes the protection of your information very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the information provided to us is stored on secure servers once we receive it.
Maldaba may store your personal data on secure servers either on our premises or in secure third party data centres. We do not transfer your personal data outside the European Economic Area (“EEA”).
Some of our service providers may transfer information they process about you outside the EEA. Where they do so, they will ensure appropriate safeguards are in place.
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Maldaba may process your data on the basis of a legitimate interest in the following ways:
- to optimise the content of our Service
- to monitor traffic and audience participation in our Service
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at firstname.lastname@example.org and telling us which communications you would like us to stop sending you.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
8. Contact Details
Alternatively, you may write to us at the following address:
Hear Me Now
125 Charing Cross Road