Privacy Policy (May 2018)

Introduction

1.1     We are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information.

Please read this Privacy Policy carefully as by visiting our website (www.tickr.co.uk), using our mobile Application(s) (App) or opening a Tickr account, you will be bound by the terms of this Privacy Policy.

1.2     We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3     Our website incorporates privacy controls which affect how we will process your personal data.

By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via account settings within the App or www.tickr.co.uk/preferences.

1.4     If you have signed up to a Tickr account this Privacy Policy should be read together with our

Customer Terms & Conditions.

1.5     In this policy, “we”, “us” and “our” refer to Tickr.

About Us

2.1     For the purpose of this Privacy Policy and the Data Protection Act 1998, Tickr Ltd of 3rd Floor, 86 – 90 Paul Street, London EC2A 4NE is the ‘data controller’.

Information we may collect from you

3.1     During the course of opening a Tickr account, the information you give to us may include your name, address, email address, phone number, date of birth, National Insurance number, bank account and other financial details, copies of personal identification documents (such as your passport or driving licence) and photographs or other descriptions of your likeness. You may also provide   us   with   certain   information   by   filling   in   other   forms,   entering   competitions   or promotions or by corresponding with us by phone, email, or text message.

3.2     When you visit our website or use our App we may collect or receive your IP address, URL, browser   information,   plug-in   types,   operating   system   and   platform   as   well   as   your   login information. We work closely with third parties (for example: business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies) and may receive information about you from them, such as your clickstream through our website and App, the products you viewed and the page interactions.

3.3     We, or our third party providers, may also use cookies to collect information about you. This helps us to provide you with a good experience while you use our website and our App. See our Cookie Policy for more details.

What we use your information for

4.1     We use the information we collect about you to:

(i)       Verify your identity and to conduct anti-money laundering checks;

(ii)       provide you with the products and services you have requested;

(iii)    carry out our contractual obligations in relation to contracts entered into with you or with our business partners and service providers;

(iv)     notify you about changes to our products or services;

(v)       ensure that content from our website and our App is presented in the most effective manner for you and for your devices;

(vi)     administer our website and App and for internal operations such as troubleshooting, data analysis, testing and research purposes;

(vii)     help maintain the safety and security of our website and App;

(viii)   make suggestions to you (and other customers) about our products or services and to send such information via email, SMS message, targeted social media and our in-App secure notification centre; and

(ix)     measure or understand the effectiveness of advertising we send to you (and other customers) and to deliver relevant advertising to you

Processing of data

5.1     We will access, use, and share the Information as required to fulfil our contractual obligations to you or subsequent requests for support by you.

5.2     We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

5.3     We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity, analyse performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.  For more information on these third parties, including how to opt out from certain data collection, please visit the site/s below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.

(I)   Google Analytics, please visit https://www.google.com/analytics

5.4     We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of providing our services,   ensuring   the   security   of   our   website   and   services,   maintaining   back-ups   of   our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5.5     We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5.6     We may process information that you provide to us for the purpose of subscribing to our email communications (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

5.7     We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata   associated   with   the   communication.   Our   website   will   generate   the   metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

5.8     We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

5.9     We may process any of your personal data identified in this policy where necessary for the purposes   of   obtaining   or   maintaining   insurance   coverage,   managing   risks,   or   obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

5.10   In addition to the specific purposes for which we may process your personal data set out in this

Section 5, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Disclosing your personal data

6.1     Advertisers and advertising networks that require the information to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymised or aggregate information about our users.

6.2     Analytics and search engine providers that assist us in the improvement and optimisation of our site (for example Google for the purpose of its Google Analytics service).

6.3     If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets.

Or if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.

6.4     if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or Apply our Website & App Terms of Use, our Customer Terms & Conditions and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Security of your information

7.1     Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 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 information transmitted to our website or App. Transmission is at your own risk.

7.2     Where we have given you, or where you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our App, you are responsible for keeping this password or PIN confidential. We ask you not to share this password or PIN with anyone.

7.3     The hosting facilities for our website are situated in the UK.

7.4     You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

8.1     Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.

8.2     We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8.3     To request erasure of your personal data please contact us at hi@tickr.co.uk.

Changes to this Privacy Policy

9.1     We may make changes to this Privacy Policy by publishing a new version on our website, so please review it every now and then to ensure you are happy with any changes.

9.2     If appropriate we will notify you by email about changes. Remember, you will be bound by this policy.

Your rights

10.1   Some of your rights under data protection law and GDPR are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

10.2   You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(i)         a small fee to cover our administrative costs, currently 10 GBP per request; and

(ii)       the supply of appropriate evidence of your identity.

To request a copy of your personal information, please email us at hi@tickr.co.uk.

10.3   We may withhold personal information that you request only to the extent permitted by law.

10.4   By submitting your personal information, you agree that we may use your information for marketing purposes (including electronic marketing). We will not disclose your information to any third party for marketing purposes, without your further consent. You have the right, at any time, to ask us not to process your personal information for marketing purposes. You can do so at www.tickr.co.uk/preferences, via your account settings within the App, or by emailing us at hi@tickr.co.uk.

10.5   Our website or App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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 information to these websites.

10.6   You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

10.7   In some circumstances you have the right to the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure including where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.

10.8   In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.

10.9   You have the right to object to our processing of your personal data on grounds relating to your particular situation. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

10.10 Legal basis for our processing of your personal data is: (i)        consent; and/or

(ii)     that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

Where such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not Apply where it would adversely affect the rights and freedoms of others.

10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

10.12 You may exercise any of your rights in relation to your personal data by emailing us at hi@tickr.co.uk.

About cookies

11.1   A cookie is a small data file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.  Additionally, mobile devices may use other tracking files which are similar to cookies (for example iOS devices use Apple’s ‘identifier for advertisers’ (IDFA) and Android devices use Google’s Android ID). In the context of tracking within an App, the concept of a cookie will include an IDFA and an Android ID for the purpose of this Cookie Policy.

11.2   Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

12.1   We may use the following cookies:

(i)      Strictly necessary cookies: these are cookies that are required for the operation of a website and App, such as to enable you to log into secure areas.

(ii)     Performance cookies: these types of cookies recognise and count the number of visitors to a website and users of an App and to see how users move around in each. This information is used to improve the way the website and App work.

(iii)    Functionality cookies: these cookies recognise when you return to a website or App, enable personalised content and recognise and remember your preferences.

(iv)     Targeting cookies: these cookies record your visit to a website or App, including the individual pages visited and the links followed.

Generally, the strictly necessary cookies and some performance and functionality cookies only last for the duration of your visit to a website or expire when you close an App: these are known as ‘session cookies’. The functionality cookies and some targeting and performance cookies will last for a longer period of time: these are known as ‘persistent cookies’.

12.2   We use cookies for the following purposes:

(i)      authentication – we use cookies to identify you when you visit our website and as you navigate our website;

(ii)       status – we use cookies to help us to determine if you are logged into our website;

(iii)    personalisation – we use cookies to store information about your preferences and to personalise the website for you;

(iv)     security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(v)       advertising – we use cookies to help us to display advertisements that will be relevant to you;

(vi)     analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(vii)     cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Generally, our website and App use cookies to distinguish you from other users. This helps us to improve our website and App and to provide you with a good experience when you browse our website or use our App.

Third party cookies

13.1   Some of the persistent and session cookies used by our website and App may be set by us, and some are set by third parties who are delivering services on our behalf. For example, we use Google Analytics to track what users do on the App so we can improve the design and functionality. Google’s privacy policy is available at: google.com/policies/privacy/.

Managing cookies

14.1   Most websites, mobile devices and Apps automatically accept cookies but, if you prefer, you can change your browser, device or App settings to prevent that or to notify you each time a cookie is set.  On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notifications when you are receiving a new cookie and how to turn cookies off.  To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest- based ads’.

14.2   Blocking all cookies will have a negative impact upon the usability of many websites.

14.3   If you block cookies, you will not be able to use all the features on our website.

Our details

15.1   This website is owned and operated by Tickr Ltd.

15.2   We are registered in England and Wales under registration number 11200977, and our registered office is at 3rd Floor, 86-90 Paul Street, London EC2A 4NE.

15.3   Our principal place of business is at 3rd Floor, 86-90 Paul Street, London EC2A 4NE.

15.4   To contact us, please email help@tickr.co.uk or by writing to the address above.