PIN SEEKERZ LIMITED, a company registered in England and Wales under company number 08903154, whose registered office is at Suite 315, 19-21 Crawford Street, London, United Kingdom, W1H 1PJ hereinafter referred to as ‘PSZ’ or ‘We’ have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using the PSZ App to access the PSZ Services. Unless otherwise indicated, all definitions used in the Pin Seekerz App User Licence shall apply to this Statement and for the purposes of this Statement, ‘Personal Data’ shall include financial data. In this Statement, references to ‘You’ and ‘Your’ are references to the PSZ Member. When You use the PSZ App to access the PSZ Services, You are consenting to the practices set forth in this Statement.
1. YOUR ACCEPTANCE OF THE STATEMENT
This Statement governs Your use of the PSZ App to access the PSZ Services (once You have downloaded or streamed a copy of the PSZ App onto Your Device), including any dispute concerning privacy and in using the same, You accept this Statement in full. You should read the Statement carefully and ensure that You understand its effect before proceeding to use the same. We reserve the right to modify this Statement at any time without notice. Any changes We may make to this Statement in the future will be notified to You by SMS or by email or when You next log in to use the PSZ App, the new terms (or a hyperlink to the new terms) may be displayed on-screen and You may be required to read and accept them to continue. You agree that PSZ will treat Your continued use of the PSZ Services as acceptance of this Statement as may be amended from time to time.
2. WHAT INFORMATION IS COLLECTED & HOW?
A. Personal Data
2.1 Upon registration as a PSZ Member, You will be asked to provide various types of Personal Data to enhance the quality of the services We can provide to You and the more accurate the information You provide, the better We are able to respond to Your requirements!
2.2 As part of the process of using the PSZ App and becoming a PSZ Member to access the PSZ Services, the relevant App Store in their capacity of a Service Provider to PSZ may collect the following types of Personal Data about You (as applicable):
(a) Your information You may submit when You register to download or use the PSZ App, or subscribe to any of our PSZ Services e.g. Your name, username, password, address, email and credit/debit card details;
(b) Your information You may submit when You share data via the PSZ App by way of the PSZ App’s social media functions, enter a competition, promotion or survey, and if You report a problem with the PSZ App or our PSZ Services;
(c) Your Personal Data (to the extent permitted by Your settings) that You have provided to a third party SM Site (e.g. Facebook) when You choose to login using the login credentials peculiar to that SM Site membership.
(d) Referral service: The PSZ App provides a referral service that allows You to invite Your friends and family members i.e. Your contacts to undergo Sign-Up. We may integrate the PSZ App with SM Sites such as Facebook so that You can send invitation messages by way of SMS messages or links direct to the Invitee which if clicked on, will transport the Invitee directly to the App Store. We will require access to Your Invitee’s email addresses to track if Your Invitee joins PSZ in response to Your referral. If You request us to import Your contacts from the relevant SM Site, We will collect, but not store, the username and password for the email account You wish to import Your contacts from. We will use this information only for the purpose of importing Your contacts and in accordance with Data Protection Legislation.
(e) Information We collect about You and Your Device. Each time You use the PSZ App, pursuant to the permitted functionality, We may automatically collect the following information:
i. technical information, including the type of Device You use, a unique device identifier (for example, Your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, Your operating system, the browser type and version You use, time zone setting, Your IP address, referral source, length of visit, page views and navigation (‘Device Information’);
ii. information stored on Your Device, including contact information, friends lists, login information, photos, videos or other digital content, check-ins (‘Content Information’);
iii. details of Your use of our PSZ App (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that You access (‘Log Information’);
iv. Location information: We may also use Global Positioning Satellites technology (‘GPS’) 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 Personal Data being used for this purpose. You can withdraw Your consent at any time but if You do so, much of the functionality of the PSZ App will not be available to You which will reduce the benefits to be gained;
v. Information We receive from other sources: We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about You from them. (‘Third Party Information’);
vi. Unique application numbers: when You install or uninstall a PSZ Service e.g. software updates, containing a unique application number or when such a PSZ Service searches for automatic updates, that number and information about Your installation, for example, the type of operating system, may be sent to us;
vii. Information We collect about the PSZ Content that You download;
viii. Your own User Generated Content (‘UGC’) that You may upload or submit to the PSZ App; and,
ix. Any other information that You choose to send to us, including any request for further PSZ Services, general correspondence, reports of a problem with the PSZ App.
B. Other Data
2.3 De-personalised data which does not record Personal Data as such, rather information such as the date of Your use of the PSZ App, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the PSZ App, to better understand how they are functioning for You and to draw conclusions upon demographic information.
C. Financial Data
2.4 Where You are paying for the PSZ Services as a PSZ Member, it is the relevant App Store (or a third party payment processor on their behalf) that will process Your PSZ Member Charges. You will be required to provide Your financial data to make Your purchase to the relevant App Store in order to authorise payment and bill You. When You make any such payment, Your consent is given to provide Your financial data necessary to process Your payments to any third party payment processor that the relevant App Store might use as their service provider. To make and complete the payment, the policies of the relevant App Store shall be applicable as between You and the App Store and can be found here (GOOGLE PLAY) and here (ITUNES). If You are using online banking, Your own bank’s terms and conditions shall apply also. Except as provided here, We will not share financial data with third parties without Your prior consent.
3. HOW IS THE INFORMATION USED?
3.1 You hereby expressly consent to Your Personal Data being passed on to third party companies or service providers for the sole purpose of fulfilling the PSZ Services only (including making improvements to the PSZ Services) (‘PSZ Service Providers’) and not for the purposes of those third parties making marketing communications to You, unless You have expressly consented to this being undertaken by a third party as described below. Although You are under no obligation to provide such Personal Data to us, if You choose not to, some if not all of the PSZ Services will not be available to You.
3.2 You acknowledge that Your Personal Data may be used by PSZ or the relevant App Store to contact a PSZ Member by post or by Electronic Mail when necessary in connection with Your use of the PSZ App using the details You provided when You requested the PSZ App. “Electronic Mail” includes email, text, video, voicemail, picture and answerphone messages (including push notifications and in-app notifications).
3.3 The relevant App Store will be able to contact You in accordance with their own privacy policies which may be updated from time to time and may be found here (GOOGLE PLAY) and here (ITUNES).
3.4 From time to time, PSZ may contact You by Electronic Mail by way of sending You various PSZ Alerts, confirmations, notifications, feedback requests or any other newsletter or offers and related information. If You change Your mind, You can opt out of receiving some of these marketing communications (as described below) but not all of these communications as some are required as a necessary part of delivering the PSZ Services to You to enable You to gain the required access.
3.5 Your Personal Data is used solely by PSZ (and PSZ Service Providers to the extent necessary to fulfil the PSZ obligations to You) for the sole purpose of enabling PSZ to act as a service provider to You and is not shared with any person or company without Your express consent.
3.6 Any Personal Data that is held with PSZ shall be retained in accordance with the Data Protection Act 1998 and related Data Protection Legislation and/ or our retention and destruction policy culminating in its permanent deletion.
3.7 We may collect and store Personal Data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
3.8 Certain PSZ Services may include social networking, chat room or forum features. Please ensure that when using these features You do not submit any Personal Data that You do not want to be seen, collected or used by other PSZ Members.
3.9 Selected third parties: If You consented to be contacted by Electronic Mail or other means by carefully selected third parties in the golfing and related sectors regarding their interesting products and/ or services, We may provide Your information to the third parties We select, and these third parties may use this information for their marketing or advertising purposes.
OPTING OUT: If You do not wish to be contacted by PSZ in respect of future marketing communications, We will give You the opportunity to unsubscribe to the receipt of such communications in every communication that We send to You.
If You no longer wish to be contacted by carefully selected third parties, You will be given the opportunity to opt-out in each communication they send to You. Please contact them directly to learn about their policies.
4. WHO HAS ACCESS TO YOUR PERSONAL DATA?
4.1 To minimise the risk of unauthorised access to Your Personal Data, the relevant SM Site will use some of Your Personal Data to authenticate You when You log in to the PSZ App.
4.2 For our daily operations, We may use the PSZ Services of third parties to provide some of our business and operational functions. Consequently, some of the PSZ Services are provided by PSZ Service Providers and We need to disclose Your information to them to provide You with the PSZ Services.
4.3 Disclosure of Your Personal Data in Compliance with Laws
You should be aware that We may release Your Personal Data when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transact or communicate with or via PSZ, or to protect the rights, property or safety of PSZ, PSZ Members or third parties.
4.4 Transfer of Your Personal Data outside of the EEA
From time to time, We may transfer Your Personal Data to a related company, agent or contractor in order to improve our PSZ Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Personal Data to such companies for the purposes set out here in accordance with this Statement and as permitted by the Data Protection Legislation from time to time. For Your information, the laws of other countries to which Your Personal Data is transferred may not provide the same level of protection for Your Personal Data as the law of Your home country. We do, however, put in place appropriate technical and contractual protections for Your Personal Data in accordance with applicable laws.
4.5 Transfer of Personal Data in the Event of the Sale of Pin Seekerz Limited or its Assets including www.pinseekerz.com
In the event that PSZ is sold or transfers some of its assets to another party, Your Personal Data could be one of the transferred assets. If Your Personal Data is transferred, its use will remain subject to this Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of PSZ.
4.6 Other Websites, Apps and their Privacy Policies and Cookie Policies
The PSZ App may contain links to other websites. PSZ is not responsible for the privacy practices or the content of such websites or for the privacy policies, cookie policies and practices of other third parties, so You should be careful to read and understand those policies independently.
5. HOW DO WE PROTECT YOUR PERSONAL DATA & FOR HOW LONG?
5.1 The privacy and protection of Your Personal Data is important to us. In addition, any PSZ Member statistics that We may provide to prospective PSZ Service Providers regarding Your usage of the PSZ Services are provided in the aggregate only and do not include any individually identifiable data.
5.2 You acknowledge that email messages sent over the internet are not encrypted and are not secure. Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any Personal Data You transmit to us, via, to, or from our PSZ App. You accept that PSZ cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential Personal Data which You do not wish to communicate by email, please contact PSZ by telephone or post to arrange an alternative method of communication. You transmit all such Personal Data at Your own risk.
5.3 How long We keep Your Personal Data collected depends on the context in which You provide it and the purpose for which We use it. We will only retain it for as long as is necessary for such purposes. We may send You direct marketing communications for as long as You do not unsubscribe from receiving the same from PSZ.
5.4 Telephone calls: If You call any of the service telephone numbers quoted, We may record Your call. These recordings are used for training and quality control to ensure that We continuously monitor and improve our service standards.
5.5 We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
7. PSZ MEMBER COMPLAINTS OR QUERIES
PSZ tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any PSZ Member Complaints We receive about this very seriously. We encourage You to bring it to our attention if You think that our collection or use of Personal Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Statement does not provide exhaustive detail of all aspects of PSZ’s collection and use of Personal Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below. If You are not happy with the way in which Your Personal Data is being handled by PSZ, You can complain to the Information Commissioner whose details can be found at: http://www.ico.org.uk/
8. ACCESS TO YOUR PERSONAL DATA
PSZ tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if We hold any Personal Data by making a ‘subject access request’ under the Data Protection Act 1998. If We do hold Personal Data about You, We will let You have a copy of that Personal Data. To make a request to PSZ for any Personal Data that We may hold, You need to put the request in writing (along with certain ID requirements) addressing it to the address provided below. They may be an administrative charge applied in accordance with the applicable legislation and We have up to forty (40) days to respond.
9. HOW TO CONTACT US
Requests for information about our Statement or a ‘subject access request’ can be emailed to firstname.lastname@example.org or by writing to:
PIN SEEKERZ LIMITED
(Internal Compliance Department)
Suite 315, 19-21 Crawford Street, London, United Kingdom, W1H 1PJ
10. CHANGES TO THIS STATEMENT
We keep our Statement under regular review. This Statement was last updated on 14 January 2015.