Privacy Policy

PALRINGO LIMITED (“we”, “us” or “our”) is committed to protecting and respecting your personal data and privacy.

This privacy policy (“Policy”) will inform you as to how we look after your personal data when you visit our Sites (as defined below) and will tell you about your privacy rights and how the law protects you.

SCOPE OF THIS POLICY

This Policy (together with our Terms of Service (“TOS”) as set out at www.palringo.com/terms-and-conditions and any additional terms of use incorporated by reference into the TOS, all together our “Terms of Use”) applies to your use of:

  • Our website www.palringo.com (“Website”);
  • The PALRINGO mobile application software (“App”), once you have downloaded or streamed a copy of the App onto your Apple or Android mobile telephone or handheld device; and
  • Any of the services accessible through the App that are available on the App site or other sites of ours (“Services”), unless the TOS states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies,

(together referred to as our “Sites”).

This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully (together with our Terms of Use) to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation ((EU) 2016/679) (as it may be implemented into national law), the data controller of your personal data is PALRINGO LIMITED, a company registered in England and Wales with company number 05801490 and its registered address at 4 Arcot Court, Nelson Park Industrial Estate, Cramlington, Newcastle Upon Tyne, NE23 1BB.

Any reference within this Policy to PALRINGO LIMITED shall be construed to include any parent, group or subsidiary company which is related or connected to Palringo Limited in accordance with the definition provided in section 1159 of the Companies Act 2006.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Our contact details are:

Company Name: PALRINGO LIMITED

Email address: support@palringo.com

Postal address: 4 Arcot Court, Nelson Park Industrial Estate, Cramlington, Newcastle Upon Tyne, NE23 1BB

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

THE INFORMATION WE COLLECT ABOUT 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 has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and location.
  • Contact Data includes email address.
  • Transaction Data includes details about payments to and from you and other details of purchases you have made (i.e. App purchases, virtual currency and goods).
  • Technical Data includes internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, app platform and version (where applicable) and other technology on the devices you use to access the Sites.
  • Profile Data includes your username and password, purchases made by you (i.e. App purchases), your messaging history, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Sites.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site 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 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. However, to the extent that you choose to provide such Special Categories of personal data onto our Sites (for example, as part of your profile), you accept that this may be viewed by other users of our Sites.

FAILURE TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel our Services but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect personal data from and about you, including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • use our Sites or Services;
    • create an account on our Sites (where applicable);
    • subscribe to our Services or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • give us some feedback; or
    • report a problem to us.
  • Automated technologies or interactions. As you interact with our Sites, we may automatically collect Technical Data about your equipment, devices, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you install or uninstall a Service which contains a unique application number or by visiting our Sites or Services employing our cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers, advertising networks (if any) and search information providers;
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
    • Identity and Contact Data from data brokers or aggregators; and
    • Identity and Contact Data from publicly availably sources.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into 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.
  • Where we have your express consent.

Purposes for which we will use your personal data:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To ensure we deliver excellent customer service in relation to the provision of our Services and Sites to you

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

Performance of a contract with you

To register you as a new user and communicate with you

(a) Identity

(b) Contact

Performance of a contract with you

To deliver our Services and:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover payment)

To manage our relationship with you which will include:

(a) Notifying you about changes to our TOS or this Policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how users use our Services)

To enable you to partake in a tournaments, challenges or complete a survey in order to monitor our Services and Sites

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how users use our Services, to develop them and grow our business)

To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Site content

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how users use our Services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our Sites, Services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of user for our Services, to keep our Sites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about Services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our Services and grow our business)


Location information:

As at the date of this Policy, we do not use any location-enabled Services. However, in the event that we do so in the future, we will not collect your location information unless you expressly request us to do so. You agree that if you let others use location based services that you have asked us to provide to you, or if you let others use your mobile handset or other terminal equipment, it is your responsibility to inform them that their location may be identified.

Third-party links:

Our Sites may, from time to time, contain links to third party websites, plug-ins and applications (including, but not limited to, websites on which the App or our Services are advertised). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy notice of every website or other application that you visit.

Marketing:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us:

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or Services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing:

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

Opting out:

You can ask us or third parties to stop sending you marketing messages at any time by logging into our Sites by following the opt-out links on any marketing message sent to you or by contacting us at any time. The opt-out links can usually be found at the end of any emails we send to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or Service purchase, product or Service experience or other transactions or any service notifications we may send to you (such as any maintenance issues on any of our Sites).

Cookies:

Our Website (and the Palringo Web Chat (www.palringo.im)) uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to make improvements.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We may from time to time use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you.
  • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose More Information

Google Analytics

Used to provide analytics on the usage of our Website and web chat.

https://policies.google.com/privacy/update?hl=en&gl=uk

Facebook

Used to power the “Login via Facebook” capability for Palringo users who choose to log in via their Facebook account.

https://www.facebook.com/policies/cookies


You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

Change of purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE OF YOUR PERSONAL DATA

We may have to share your personal data with external third parties for the purposes set out in this Policy.

This will include (but is not limited to) third parties set out in the below table and those third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, our third party service providers, to our professional advisors and to HM Revenue and Customs. 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 Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third Party Name Reason for Disclosure More Information

Amazon Web Services (AWS)

AWS is a “processor” of our data.  We use various modules within the services AWS can provide.  We have permanent databases and file storage, temporary stores and we use services to process our data.

https://aws.amazon.com/compliance/gdpr-center/

Zendesk Inc

Our customer support system is provided by Zendesk.  User IDs will appear in Zendesk along with all discussion between users and ourselves.

https://www.zendesk.com/company/customers-partners/privacy-policy/

Appsflyer

We use Appsflyer for tracking use of our App by collecting IP addresses and device identifiers.  Personal data is collected though their SDK. Appsflyer have confirmed that all of their data is stored on EU-based servers owned by AWS and Google Cloud.

https://www.appsflyer.com/product/gdpr

Google Firebase

Used to provide analytics on the performance of our Apps.  Data collected via a Google SDK.

https://firebase.google.com/support/privacy/

Fabric.io

Used to provide analytics on the performance of our Apps.  Data collected via a Google SDK.

https://fabric.io/blog/2018/3/27/fabric-gdpr-compliance

Google Analytics

Used to provide analytics on the usage of our Website and web chat.

https://policies.google.com/privacy/update?hl=en&gl=uk

Adyen B.V.

Adyen act as a payment aggregator for our financial transactions via our web store, in particular payments via credit cards and a small number of other payment methods.

 

Paypal Inc

Payment merchant that can be used via our Website.

https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev

Cashu

Provide users with MENA based payment methods.  They are based outside of the EEA.

https://www.cashu.com/site/privacyPolicy

iTunes

In app payment processing for users with iOS devices.

https://www.apple.com/uk/legal/privacy/en-ww/

Googleplay

In app payment processing for users with Android devices.

Please see Google Analytics above.


WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA).

For example, some of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

By using our Sites you agree that your personal data may be transferred, stored and processed outside of EEA on this basis.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have 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.

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.

Ensure when using the Services that include any social, chat or forum features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal 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 purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will hold your messaging history for a period of one month from termination of services, after which it will be deleted.

Details of retention periods for different aspects of your personal data are available on request from us by contacting our data privacy manager.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact our data privacy manager.

You have the right to:

  • 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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. We will advise you if this is the case at the time you withdraw your consent.

Access to your information:

In the event that you wish to exercise any of your legal rights set out above, we shall endeavour to deal with your request by complying with the following conditions:

  • No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
  • What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

CHANGES TO THIS OR YOUR PERSONAL DATA

Any changes we may make to this Policy in the future will be posted on this page and, where appropriate, notified to you when you next use our Sites. The new Policy may be displayed on-screen and you may be required to read and accept them to continue your use of our Sites and Services.

This version was last updated in May 2018.

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 your relationship with us.

CONTACT

Questions, comments and requests regarding this Policy are welcomed and should be addressed to us at support@palringo.com or 4 Arcot Court, Nelson Park Industrial Estate, Cramlington, Newcastle Upon Tyne, NE23 1BB.