Padoq Limited (we/us) are committed to protecting the privacy and security of your Personal Information.
This privacy notice describes how we collect and use Personal Information about you in accordance with the General Data Protection Regulation (GDPR) and any subsequent or associated data protection legislation in force from time to time (Data Protection Legislation).
* the Padoq mobile application software (App) available on the Google Play store at [INSERT LINK] or the Apple App store at [INSERT LINK] (App Sites) once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Please see our VALUES STATEMENT as to the criteria we will use to make judgments and interpretations as scenarios and cases occur. Please remember you are entitled to leave PADOQ at any time and there is a mechanism for your Personal Information to be deleted from the App. We will only retain data where we are required to do so by legal or accounting obligations.
Padoq Limited is a "Data Controller". This means that we are responsible for deciding how we hold and use Personal Information that we hold about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.
This notice applies to all users of the App. 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 Information about you, so that you are aware of how and why we are using such information.
The nature of the Services is that any user of the App can create Padoqs. If a user creates a Padoq then they are the administrator of that Padoq (Padoq Administrator). Padoq Administrators are individual users of the App; they are not representatives of Padoq and do not represent us or our views.
When you join a Padoq you may be required to provide additional information to the Padoq Administrator so they can operate the Padoq (Padoq Data). The Padoq Administrator will be a Data Controller of the Padoq Data and we may act as a Data Processor on their behalf. Our compliance team may also access the Padoq Data from time to time to moderate content or cooperate with law enforcement. Any enquiries in relation to the Padoq Data should be directed towards the relevant Padoq Administrator. We accept no responsibility or liability in relation to the Padoq Data. We will only access Padoq Data where required to support our platform safety, legal & regulation responsibilities as we have no intention of making money from or misusing your Personal Information -- see our VALUES STATEMENT.
Data protection principles
We will comply with data protection law. This says that the Personal Information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely. The kind of information we hold about you
Personal Information (or Personal Data) means any information about an individual by which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data related to a Padoq.
We will collect, store, and use the following categories of Personal Information about you:
Personal contact details such as username and personal email addresses.
- Date of Birth.
- Gender (optional).
- Location information - Precise GPS from mobile devices is collected only with your permission. WiFi and IP addresses received from your browser or device may be used to determine approximate location. You can turn off location services through your Device settings or the App settings.
- Your networks and connections - We collect information about the people and Padoqs you are connected to and how you interact with them, such as the Padoqs you engage with the most or the Padoqs you join.
- Information about payments - If you use our Services for purchases or financial transactions (e.g. when you transfer money to another App user or pay us for additional features), we collect information about the purchase or transaction. This includes a record of that transaction.
Information we collect about you and your device. Each time you visit one of our Sites or use the App we will automatically collect the following information:
* technical information, including the type of mobile 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 mobile operating system, the type of mobile browser you use and time zone setting (Device Information);
* information you upload to the App, such as photos and files (Content Information);
* details of your use of any of the App or your visits to any of our Sites including, but not limited to traffic data and other communication data, whether this is required for our own billing purposes or otherwise.
* information about your online and status message changes on our Services, such as whether you are online (your "online status").
Information we receive from other sources (Third Party Information). 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). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Information about your use of our information and communications systems.
How is your Personal Information collected?
We collect Personal Information about you through the App and our websites.
How we will use information about you
We will only use your Personal Information when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
1. Where we are providing the Services to you.
2. Where we need to comply with a legal or regulatory obligation.
3. 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 (including to keep the App safe for everyone in line with our VALUES STATEMENT).
We may also use your Personal Information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else's interests).
2. Where it is needed in the public interest.
Situations in which we will use your Personal Information
We need all the categories of information in the list above (see section headed "The kind of information we hold about you") primarily to allow us to provide the Services to you and to enable us to comply with legal obligations under UK law. In some cases we may use your Personal Information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your Personal Information are listed below. We have indicated the purposes for which we are processing or will process your Personal Information, as well as indicating which categories of data are involved.
We use information held about you in the following ways:
Email, Date of birth - This information is required to identify you as a user and verify your age to ensure you are not privy to inappropriate content.
We will monitor the device used by the user to optimise their experience of the App, provide relevant advertising and manage cross platform consistency/synching.
We will also monitor the device as part of our analytics towards App usage and performance.
We will monitor content to investigate reports of inappropriate behavior and / or violations of our VALUES STATEMENT.
We will use log information to monitor engagement on the platform from an analytical perspective. This will be anonymised to a per Padoq level.
We will monitor access logs to spot suspicious activity with regard to money laundering / fraud and security breaches.
We use location services to improve user experience and suggest relevant content (such as new Padoqs) to them.
We use location for analytical purposes.
We will use location as part of behavioral based advertising.
Setting up your Padoq - We store the location against the Padoq.
Third Party Information:
When setting up your E-Wallet on Padoq we collect the following information to complete a KYC check (Know your customer). This information goes directly to the appropriate (initially Mangopay) payment provider (we do not store or see this).
- Income Range
- Date of birth
- Passport / ID check (photo upload).
We may associate any category of information with any other category of information and will treat the combined information as Personal Information in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1).
We may use some Personal Information to improve an advertiser's targeting, but this will never include targeting or identifying you as an individual. Our approach is to serve adverts to members of a Padoq which they see when they are logged on. Whilst we may reduce the displays of an advert using attributes such as gender, age, location, frequency of visit; we will not compromise nor supply identifiable information to advertisers; you always have the power and choice to opt-into a relationship with the advertiser from a previously anonymous starting point (in terms of Padoq).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Personal Information.
If you fail to provide Personal Information
If you fail to provide certain information when requested, we may not be able to provide the Services.
Change of purpose
We will only use your Personal Information 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 Information 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 Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated decision-making takes place when an electronic system uses Personal Information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We will not transfer your Personal Information outside the EU, however if you access the App from outside the EU then data will be streamed outside the EU.
You can expect a similar degree of protection in respect of your Personal Information.
Why might you share my Personal Information with third parties?
We will share your Personal Information with third parties where required by law, where it is necessary to provide the Services to you or where we have another legitimate interest in doing so. Well will not sell your Personal Information to advertisers.
Which third-party service providers process my Personal Information?
"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group. For example, Mangopay will collect and process your Personal Information for banking purposes (such as name and bank account details).
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Information in line with our policies. We do not allow our third-party service providers to use your Personal Information for their own purposes. We only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
When might you share my Personal Information with other entities in the group?
We will share your Personal Information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
What about other third parties?
We may share your Personal Information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your Personal Information with a regulator or to otherwise comply with the law.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any Personal Information that you do not want to be seen, collected or used by other users.
We have put in place measures to protect the security of your information.
Third parties will only process your Personal Information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who need to know that information. They will only process your Personal Information 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 we will engage with the community to keep you and any applicable regulator informed when there is a suspected breach.
How long will you use my information for?
We will only retain your Personal Information for a period of 6 months from the date you delete your Padoq account, or for such longer period as may be required to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your Personal Information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
If you delete your Padoq account then you will appear as a 'deleted user' however any content you posted in Padoqs will remain unless manually deleted by yourself before you delete your account.
Rights of access, correction, erasure, and restriction
Your rights in connection with Personal Information
Under certain circumstances, by law you have the right to:
Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information 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 Information. This enables you to ask us to delete or remove personal information 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 Information where you have exercised your right to object to processing (see below). To exercise this right you will have to leave the App with no right of return.
Object to processing of your Personal Information 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 Information for our direct marketing purposes.
Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Information to another party. To exercise this right you will have to leave the App with no right of return.
If you want to review, verify, correct or request erasure of your Personal Information, object to the processing of your Personal Information, or request that we transfer a copy of your Personal Information to another party, please contact email@example.com in writing.
No fee usually required
You will not have to pay a fee to access your Personal Information (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
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information 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 firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Your duty to inform us of changes
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your use of the App.
Data protection officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your Personal Information, please contact the DPO. 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.
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 Information.
If you have any questions about this privacy notice, please contact (Data Protection Officer, DPO@padoq.com)