WHAT IS THE PURPOSE OF THIS DOCUMENT?
Eat Play Change (EPC, our, us or we) is committed to protecting the privacy and security of your personal data.
This privacy notice describes how we collect and use the personal data of individuals we do business with (also referred to in this notice as ‘you‘). This includes our current, former and prospective users, complainants and enquirers.
This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such data.
Data Controller
EPC is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
THE KIND OF DATA WE HOLD ABOUT YOU
“Personal data” 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). There are “special categories of personal data” which require a higher level of protection. These include information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health or condition or sexual life.
We may collect, store, and use the following categories of personal information about you:
A. Identity Data: first name, last name, title, date of birth, gender, user ID number.
B. Contact Data: email address, telephone number, mobile number.
C. Profile Data: username, password, your queries and complaints, your interests, preferences and feedback responses, records of our communication with you, details about how you use our products/services, any contraventions by you of our rules and regulations, user ID number.
D. Financial Data: payment details.
E. Transaction Data: details about payments to and from you and other details of products/services you have purchased from us.
F. Marketing Data: your preferences in receiving marketing from us and our third party service providers and your communication preferences.
G. IT Data: information about your use of our information and communications systems and website.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect data directly from you through the user registration process and your interactions with the App and our website and we may create some data internally (for example, we assign you a user identification number).
We will also collect additional personal data throughout the period you remain a user or you continue to interact / work with or provide a service to us or purchase products/services from us.
HOW WE WILL USE DATA ABOUT YOU
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 service you have registered for
-
Where we need to comply with a legal obligation.
-
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.
We may also use your personal data, which is likely to be rare, where we need to protect your interests (or someone else’s interests).
Situations in which we will use your personal data
Below describes the legal basis that applies to our purposes for processing your personal data. Depending on the circumstances, more than one legal basis may apply.
Purposes:
Managing our relationship with you including notifying you of changes to our terms or privacy policy or asking you for your feedback on our services/products, recording our communications with you, for regulatory purposes
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; Necessary for our legitimate interests to maintain our relationship with you, keep our records updated and to study how you use our products/services; and Necessary to comply with a legal obligation
Purposes:
Administration
Category of Personal Data:
Categories: A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you;
Purposes:
Performing enquiries, investigations and complaints Necessary for our legitimate interest for running and growing our business, ensuring compliance with our regulations and studying the engagement with our services
Category of Personal Data:
Categories: A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; Necessary for our legitimate interest for running, maintaining and growing our business
Purposes:
Respond to your queries and assist you with your requests
Category of Personal Data:
Categories A, B, C, E, F, G
Lawful basis for processing:
Performance of a contract with you
Purposes:
Managing subscriptions to our products and services
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you
Purposes:
To process and deliver orders for our products/services including (a) manage payments, fees and charges; (b) collect and recover money owed to us
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; and Necessary for our legitimate interests to recover debts due to us
Purposes:
To send you relevant communications including marketing and to make suggestions and recommendations to you about products/services that may be of interest to you
Category of Personal Data:
Categories A, B, C, E, F, G
Lawful basis for processing:
Necessary for our legitimate interests to develop our products/services and grow our business
Purposes:
Administering the contract we have entered into with you
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you
Purposes:
Business operation, management and planning, including accounting and auditing
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Necessary for our legitimate interests for running, managing and growing our business; Necessary to comply with a legal obligation
Purposes:
Dealing with legal disputes
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; Necessary for our legitimate interests for running and maintaining our business; Necessary to comply with a legal obligation
Purposes:
To prevent fraud
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Necessary for our legitimate interests for running, maintaining and protecting our business; Necessary to comply with a legal obligation
Purposes:
To monitor your use of our information and communication systems to ensure compliance with our IT policies and regulations
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; Necessary for our legitimate interests for running, maintaining and growing our business as well as protecting our IT systems and security; Necessary to comply with a legal obligation
Purposes:
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
Category of Personal Data:
Categories A, B, C, D, E, F, G
Lawful basis for processing:
Performance of a contract with you; Necessary for our legitimate interests for running, maintaining and growing our business as well as protecting our IT systems and security; Necessary to comply with a legal obligation
If you fail to provide personal data
If you fail to provide certain data when requested, we may not be able to perform the contract we have entered into with you (such as providing a service to you) or we may be prevented from complying with our legal obligations.
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 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.
AUTOMATED DECISION-MAKING
We do not envisage that any decisions will be taken about you using automated means. However we will notify you in writing if this position changes.
DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: credit card and payment providers, App platform support and hosting, website hosting, IT service and support providers.
How secure is my data with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When will you share my data with third parties?
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of our business.
We may also need to share your personal data with a regulator, law enforcement authorities or to otherwise comply with the law.
Transferring Data outside the EU
We may transfer your personal data outside the EU. If we do, you can expect a similar degree of protection in respect of your personal data.
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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
DATA RETENTION
How long will you use my data for?
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.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such data without further notice to you. Once you are no longer an App user or your relationship with us has ended (for whatever reason), we will retain and securely destroy your personal data in accordance with our data retention policy.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
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 working relationship with us.
Your rights in connection with your personal data
Under certain circumstances, by law you have the right to:
-
Request access to your personal data. 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 information we hold about you corrected.
-
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 exercised your right to object to processing (see below).
-
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. You also have the right to object where we are processing your personal data for direct marketing purposes.
-
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
-
Request the transfer of your personal data to another party.
If you want to exercise any of the above rights, please contact Úna Maguire by email to eatplaychange2018@gmail.com.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you and Response Time to Request
We may need to request specific information from you to help us confirm your identity and ensure your right to access the data (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event within one month of receipt of your request. 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.
CHILDREN’S PRIVACY
EPC does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the service. The service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we have any information from a child under 13 please contact us ateatplaychange2018@gmail.com.
RIGHT TO WITHDRAW CONSENT
In circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact eatplaychange2018@gmail.com. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PRIVACY CONTACT
If you have any questions about this section or how we handle your personal data, please contact Úna Maguire at eatplaychange2018@gmail.com. You have the right to make a complaint at any time to the Data Protection Commissioner’s Office (DPC), the Irish supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the DPC, so please contact us in the first instance.
LOG DATA
EPC want to inform you that whenever you use our Service, in a case of an error in the app, data is collected and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilising the apps Service, the time and date of your use of the Service, and other statistics.
COOKIES
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your device internal memory. This Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collection information and to improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
ANY QUERIES?
If you have any questions about this privacy notice, please contact Úna Maguire at eatplaychange2018@gmail.com
Last Updated: May 2018