Effective Date: 13th August, 2021
The privacy of your data is of great importance to us. We use the personal data we collect from you when you use any Access Point, or access a Guardian Interface. Your personal data is used for specific purposes as further explained in this Policy; we do not seek to use or distribute your personal data for any other purpose or in any other manner.
We collect contact information, biographical details, preferences, and other declared personal information about you when you provide it to us. For example, when you fill out our online forms, engage with the Website or App chatbot, respond to our communications, register and use our App, enquire about, or register for, our products and services, engage in the Squads feature or otherwise message on an Access Point platforms, or participate in a reader forum or poll (which could be on any medium). Such data can include your name, date of birth, email address, postal address, phone number, mobile number, financial details, such as payment cards you use to purchase products/services or otherwise support our conservation and related activities.
You acknowledge and accept that in the event:
When you download our Apps, we will collect the following information from your device: unique identifier (UDID), MAC address or other applicable device identifier and location.
The App will require affirmative consent from you prior to accessing your contact list. Such contact information may be uploaded to our servers for the purposes of enabling you to better connect with other Guardians in your existing network. This is achieved through the syncing of contacts in order to identify Guardians within your contact list.
If you provide us with any information pertaining to other persons, whether when interacting with the Squads feature, gifting SGCs, allowing access to your contacts, or otherwise, then you shall remain responsible for and shall indemnify us from any claims or costs pertaining to, the provision of such information and its use in relation to electronic communications or use within an Access Point or any other use permitted under this Policy.
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by others (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in public areas, and you acknowledge that this may be collected and used by third parties.
We may ask data management and consumer insight providers if they have lifestyle, demographic, household information or other insights about you. This information helps us better understand our audiences. For more information on how to control this use of your information, see the section below on Controlling Your Information.
When you use third party payment providers, to pay for or receive payment from us, we will receive information including your name, email address, billing or other address, phone number (if applicable), date of sign-up, the number of payments you have received from verified PayPal users, whether you have been verified to have control of a bank account and any other information you agree they can share.
Other organisations that provide products and services to you may also share information with us. For example, they may notify us when you move home or when the payment card you used with us is renewed or replaced, so that we can keep your information accurate and up to date. This also helps ensure that you do not lose access to our products and services. We also may receive information from our partners about their customer database. This allows our partners to see if they can reach their audiences on our platforms. Generally, we will receive aggregated information rather than individual information, although your information may be used to generate these insights.
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending any information, including personal data, via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to an Access Point and so you provide it at your own risk.
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this Policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a product/service. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from social or marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.
Our legal bases for using your personal data may be any one or more of the following:
We do not aim any of our products or services directly at children under the age of thirteen (13) and we do not knowingly collect personal data about children under thirteen (13). Some of our services may have a higher age restriction and this will be shown at the point of registration. We also note that California law prohibits sale of personal data of consumers between 13-16 years of age unless the legal guardian has authorized the sale. We comply with this requirement.
We share your personal data with other organisations that are not directly linked to us under the following circumstances:
Service providers - We may share your data with other organisations that provide services on our behalf. We may do this to perform a contract we have entered into with you, where it is in our legitimate interests or with your consent. Examples of when we may share your data with service providers include sharing with:
Agencies and authorities if required by law - We may reveal your personal data to any law enforcement agency, court, regulator, government authority, or in connection with any legal action if we are required to do so to meet a legal or regulatory obligation, where the request is proportionate, or otherwise to protect our rights or the rights of anyone else (for example, in response to valid and properly served legal process such as subpoena or warrant). We will attempt to notify you prior to disclosing your data unless (i) prohibited by applicable law from doing so, or (ii) there are clear indications of unlawful conduct in connection with your use of our services.
Event sponsors and partners - we may share your personal data with sponsors of the Company’s events and partners who we hold events with for marketing purposes when you have given your permission for us to do so.
Social media organisations - We may share your personal data with other organisations when our web pages use social plug-ins from these organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, personal data they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
From time to time we may send you service emails, for example, with special offers relating to guardianship of SGCs, telling you your guardianship is coming to an end, informing you of a gift of SGCs that has been made to you, providing you with updates on transactions relating to, and status of, SGCs, or thanking you when you contribute or place an order with us.
If we have your permission, we may send you materials we think may interest you, such as new offers and updates. Depending on your marketing preferences, this may be by email, phone, or SMS.
We offer an editorial newsletter. You can manage your subscription to these emails through your profile page when you are signed in to your Guardian Account.
You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email or through your email preferences in the tab “Email Preference” when you are signed in to your Guardian Account.
Sometimes we may contact you for market research purposes, for example about a survey. You can opt out from being contacted in this way by signing into your Guardian Account and going to the tab “Email Preference”.
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
If you elect to use the “do not sell” button, we will not recontact you about that choice for at least twelve (12) months.
You have a number of rights with regard to the personal data that we hold about you and you can contact us with regard to the following rights in relation to your personal data:
If you would like to exercise any of your rights specified above, please email [email protected]. We will aim to deal with requests within one (1) month.
We may need to request specific information from you to help us confirm your identity. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one (1) month to respond. You will not have to pay a fee to obtain a copy of 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.
Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:
If you want to make any of these requests, please contact us at [email protected]. We will deal with requests for access to your personal data within forty-five (45) days for California-specific requests.
To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act. We may need to request specific information from you to help us confirm your identity.
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Cookies, device identifiers, or other information can be stored or accessed on your device for the purposes presented to you further below. These may be placed either directly by us or by third parties. Third parties such as Cloudflare, Firebase, Google Analytics, Facebook Auth, Twitter Auth, serve cookies through our websites for analytics and other purposes.
You can set your browser not to accept cookies, through the appropriate preferences or settings on the browser used to access our Websites. Since cookies are used throughout our Websites, disabling them may prevent you from using certain parts of such Websites.
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