Privacy Policy

SOCIABILITY – PRIVACY POLICY


Last Modified or Reviewed: 1 January 2024


Sociability Ventures Ltd ("We", “Sociability”, “Us”) are committed to protecting and respecting your privacy.


This Privacy 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 when you use our app, on mobile or web, (“App”) or visit our website (“Site”) (together, the “Platform”).


Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.


The Platform is not intended for children and we do not knowingly collect data relating to children.


For the purpose of the Data Protection Act (UK) 2018 (the "Act"), the data controller is:


Sociability Ventures Ltd (11796473),
The Fisheries,
1 Mentmore Terrace,
London, E8 3PN
UNITED KINGDOM


If you have any questions about this privacy policy or our privacy practice, you may contact us by email to privacy@sociability.app You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues. However, we would appreciate the opportunity to deal with your concerns before you approach the ICO, so please contact us in the first instance.


It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.


Information we may collect


We may collect and process the following data about you:


  • Identity Data such as your first and last name, username or similar identifier.

  • Contact Data such as your billing address, email address.

  • Technical Data including your IP address, login data, browser type and version, time zone setting and technical location data, operating system and other technology that you use to access the Platform.

  • Usage Data including information about how you use our Platform and our services.


We do not use your personal information to display targeted marketing and advertising to you within the Platform or via email, however, we may do this in the future. Before we do this, we will notify you of how you can opt-out. 


We collect, store and process all information strictly in accordance with this Privacy Policy. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. We may collect certain information about your disabilities, health conditions or accessibility needs (“Health Data”) in order to provide you with the best services, but we will only do so upon your express consent. Additionally, we will collect active location data (“Active Location Data”) in order to improve the use of our services to you, but only with your express consent.


This may include background location data collected even when the Platform is not in use. If you decide to withdraw consent or turn off active location tracking, then there may be some elements of our Platform that you cannot access, or aspects of our services which will not work for you. If we need to collect personal data by law or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter with you (such as providing you with our services). In this case, we have to cancel our services to you, but we will let you know at the time.


How we collect your Personal Data


We may collect your personal data through the following ways:


  1. Direct Interactions: You may give us your Identity and Contact information by corresponding with us or accessing the Platform. This includes personal data you provide when you:

    1. register to use our App or Site;

    2. subscribe to use our services;

    3. report a problem with our Platform;

    4. complete a survey that we ask you to complete for research purposes; or

    5. sign up to receive marketing, news or updates.


  1. Automated technologies or interactions: As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns.


  1. Third parties or other available sources.


We may use third parties to collect your data or access public sources as follows:

  1. Technical Data from analytics providers (such as Google, Mixpanel, Hotjar);

  2. Identity Data from social networking sites (such as Facebook, Instagram, Twitter or LinkedIn);

  3. Identity Data from third party login services (such as Facebook, Google or Apple);

  4. Identity and Contact Data from publicly available sources (such as Companies House).


  1. Cookies

Our website uses cookies to distinguish you from other users of our Site. This helps us to provide you with a better experience when you browse our Site and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them, please email privacy@sociability.app.


Where we store your personal data

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your 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 data, we cannot guarantee the security of your data transmitted to our Platform; 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.


Uses made of your information

We will only use your personal data when the law allows us to; primarily 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; and

  • where we need to comply with a legal obligation.


We have set out below, in table format, a description of all the ways we will use your personal data and which of the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Contact us if you need details about the specific legal ground we are relying on below.

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To register you as a new
user or customer

  1. Identity

  2. Contact

  3. Health

  4. Technical

  1. Performance of a contract with you

  2. with your consent (as to Health data)

To manage our relationship with you which will include: 

  1. notifying you about changes to our terms or privacy policy; 

  2. asking you to leave a review or take a survey 

  1. Identity

  2. Contact

  3. Technical

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation 

  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 

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

  1. Identity

  2. Contact 

  3. Technical

  4. Health

  5. Active Location  

  1. 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)

  2. Necessary to comply with a legal obligation 

  3. With consent as to Health and Active Location data 

To deliver relevant content within the Platform and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

  1. Identity  

  2. Contact  

  3. Usage  

  4. Technical  

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 

To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences 

  1. Technical 

  2. Usage  

  3. Health 

  4. Active Location 

  1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)  

  2. With your consent as to Health and Active Location data 

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To register you as a new
user or customer

  1. Identity

  2. Contact

  3. Health

  4. Technical

  1. Performance of a contract with you

  2. with your consent (as to Health data)

To manage our relationship with you which will include: 

  1. notifying you about changes to our terms or privacy policy; 

  2. asking you to leave a review or take a survey 

  1. Identity

  2. Contact

  3. Technical

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation 

  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 

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

  1. Identity

  2. Contact 

  3. Technical

  4. Health

  5. Active Location  

  1. 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)

  2. Necessary to comply with a legal obligation 

  3. With consent as to Health and Active Location data 

To deliver relevant content within the Platform and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

  1. Identity  

  2. Contact  

  3. Usage  

  4. Technical  

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 

To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences 

  1. Technical 

  2. Usage  

  3. Health 

  4. Active Location 

  1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)  

  2. With your consent as to Health and Active Location data 

Purpose/Activity

Type of Data

Lawful basis for processing including basis of legitimate interest

To register you as a new
user or customer

  1. Identity

  2. Contact

  3. Health

  4. Technical

  1. Performance of a contract with you

  2. with your consent (as to Health data)

To manage our relationship with you which will include: 

  1. notifying you about changes to our terms or privacy policy; 

  2. asking you to leave a review or take a survey 

  1. Identity

  2. Contact

  3. Technical

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation 

  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) 

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

  1. Identity

  2. Contact 

  3. Technical

  4. Health

  5. Active Location  

  1. 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)

  2. Necessary to comply with a legal obligation 

  3. With consent as to Health and Active Location data 

To deliver relevant content within the Platform and advertisements to you and measure or understand the effectiveness of the advertising we serve to you 

  1. Identity  

  2. Contact  

  3. Usage  

  4. Technical  

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 

To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences 

  1. Technical 

  2. Usage  

  3. Health 

  4. Active Location 

  1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)  

  2. With your consent as to Health and Active Location data 

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.


Disclosure of your information


We may disclose your personal information to third parties:if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of Sociability, our users, our subscribers, our customers, or others; and/or if Sociability or substantially all of its assets are transferred to a third party, in which case personal data held by it about its users, subscribers, customers and others will be one of the transferred assets.


Links to external sites


Our Platform contains links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


Access to information


The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.


International Transfers


We do not transfer your personal data outside the UK.



Data Retention


We will only retain your personal data for so long as reasonably necessary to fulfill the purposes we collected it for, including for any legal, regulatory, tax, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period, 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.


Deactivating your account


To deactivate your account, please email privacy@sociability.app to confirm. This will result in the removal your account and your personal data from our database and secure servers. You will lose access to the Platform, although you are able to sign up again at any time in the future, of course!


Change to our privacy policy


Sociability may make updates to this privacy policy at any time. Any changes that we may make in the future will be posted online at https://sociability.app/privacy. We will also update the Last Updated information immediately upon making any change.


Your legal rights


You have rights under data protection laws in relation to your personal data. 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 could refuse to comply with your request in these circumstances.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.We try to respond to all legitimate requests within one month. Occasionally it could 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.

You have the right to:

  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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: If you want us to establish the data's accuracy.Where our use of the data is unlawful but you do not want us to erase it.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. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  6. 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.

  7. 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.


Contact


Questions, comments and requests regarding this data protection and privacy policy are welcomed and should be addressed to privacy@sociability.app. data. Contact us if you need details about the specific legal ground we are relying on below.

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.


Disclosure of your information


We may disclose your personal information to third parties:if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of Sociability, our users, our subscribers, our customers, or others; and/or if Sociability or substantially all of its assets are transferred to a third party, in which case personal data held by it about its users, subscribers, customers and others will be one of the transferred assets.


Links to external sites


Our Platform contains links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


Access to information


The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.


International Transfers


We do not transfer your personal data outside the UK.


Data Retention


We will only retain your personal data for so long as reasonably necessary to fulfill the purposes we collected it for, including for any legal, regulatory, tax, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period, 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.


Deactivating your account


To deactivate your account, please email privacy@sociability.app to confirm. This will result in the removal your account and your personal data from our database and secure servers. You will lose access to the Platform, although you are able to sign up again at any time in the future, of course!


Change to our privacy policy


Sociability may make updates to this privacy policy at any time. Any changes that we may make in the future will be posted online at https://sociability.app/privacy. We will also update the Last Updated information immediately upon making any change.


Your legal rights


You have rights under data protection laws in relation to your personal data. 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 could refuse to comply with your request in these circumstances.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.We try to respond to all legitimate requests within one month. Occasionally it could 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.

You have the right to:


  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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: If you want us to establish the data's accuracy.Where our use of the data is unlawful but you do not want us to erase it.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. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  6. 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.

  7. 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.


Contact

Questions, comments and requests regarding this data protection and privacy policy are welcomed and should be addressed to privacy@sociability.app. data. Contact us if you need details about the specific legal ground we are relying on below.