Last Updated on: 14 MAY 2019
) describes how Ollywan Limited (“Company”
, and “our”
) collects, uses and shares personal data of users of this mobile software application (together, the “App”
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We will post any modifications or changes to the Policy on our App. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. If we make any material change to the Policy, we will post a notice on our App prior to such change taking effect.
We will only process your personal data in accordance with applicable data protection and privacy laws. For the purpose of EU data protection legislation, the data controller is Ollywan Limited of 33 Calshot Way, Enfield, Middlesex, EN2 7BQ, United Kingdom.
INFORMATION WE COLLECT
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” means any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number. We collect information about you in the following ways:
Information You Give Us.
Information From Social Networking Apps.
- the personal data that may be contained in any photo, comment or tag you upload or post to the App or when you provide us with feedback;
- the personal data you provide (including any bank details you provide) in order for us to pay any commission you may be eligible for in connection with your use of the App;
- the personal data you provide in connection with promotions we run on the App;
- the personal data you provide when you report a problem with our App or when we provide you with customer support; and
- the personal data you provide when you correspond with us by phone, email or otherwise.
Our App includes interfaces that allow you to connect to the App via Facebook and Instagram (each a “social networking site” or “SNS”). When you connect to our App via an SNS, you authorise us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information Automatically Collected.
We automatically log information about you and your mobile device when you access our App. For example, when visiting our App, we log your mobile device operating system name and version, and your mobile device manufacturer and model.
USE OF PERSONAL DATA
We use your personal data as follows:
SHARING OF PERSONAL DATA
- to operate, maintain, and improve our App, products and services;
- to pay any commission you may be eligible for in connection with your use of our App;
- to operate and administer promotions you participate in on our App;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
- as described in the Sharing of Personal Data section below.
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
With Third Party Online Stores. If you upload a photo to our App, you may tag this photo with links to the same or similar products which may be available to purchase via third party online stores. We may provide the photo you have uploaded to our App and your name to the relevant online store. If you click on a tag which links and redirects you to an online store, we may provide your name to the relevant online store. Ollywan will not make available to any online store any information other than the information described in this paragraph. However, please note that if you tag a photo with a link to an online store, or if you click on a tag which links and redirects you to an online store, that online store will have its own privacy policies and we do not accept any responsibility or liability for that online store’s apps, websites, features or policies. Please read their privacy policies before you submit any data to them.
Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share personal data as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use anonymous data for any purpose and to disclose anonymous data to third parties in our sole discretion.
THIRD PARTY SITES
Our App may contain links to third party apps, websites and features, including the third party online stores referred to in the Sharing of Personal Data
section above. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their apps, websites, features or policies. Please read their privacy policies before you submit any data to them.
USER GENERATED CONTENT
You may share personal data with us when you submit user generated content to our App, including when you submit photos, tags and comments on our App. Please note that any information you post or disclose on our App will become public information, and will be available to other users of our App and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our App. Such personal data and other information will not be private or confidential once it is published on our App.
INTERNATIONAL DATA TRANSFER
We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information
You may access the personal data we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Information
section below. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
You can also contact us using the details in the Contact Information
section below to delete or update your personal data or correct any inaccuracies in the personal data we hold about you. In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data that you have provided to us. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you enter a promotion, you may not be able to change or delete the personal data provided until after the completion of such promotion).
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
OUR POLICY ON CHILDREN
Our App is not directed to children under 15. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.
SENSITIVE PERSONAL DATA
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the App or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit a photo or other user generated content to our App, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Site.