Skiffl Limited (“we”, “us” or “our”) is committed to protecting and respecting your privacy. We own and operate www.skiffl.com (the “Website”) and the “Skiffl” downloadable mobile application (the “App”).
Together, the Website and the App are the “Access Points”, and the mobile device onto which you download the App is a “Device”. In this Privacy and Cookies Policy, references to “you” are to any person who submits data to us or an Access Point about him/herself or about any living individual in relation to use of the Access Points or the services that are available through the App or that we otherwise make available (the “Services”). When you access the Services, we may ask you to provide us with information about you. This Privacy and Cookies Policy sets out how we might use that information.
This Privacy and Cookies Policy (together with our EULA if you are using the App, and any other documents referred to in them) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Privacy and Cookies Policy carefully to understand our views and practices regarding your personal data and how we will treat it.
We will only use your personal data in the manner set out in this Privacy and Cookies Policy. We will only use your personal data in a way that is fair to you. We will only collect personal data where it is necessary for us to do so and where it is relevant to our dealings with you. We will only keep your personal data for as long as it is relevant to the purpose for which it was collected or for as long as we are required to keep it by law.
For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Skiffl Limited of 26 Greek Street, Stockport, Cheshire, United Kingdom, SK3 8AB. Our registration number with the Information Commissioner’s Office is ZA234218.
1. Information we may collect from you
1.1 We may collect and process the following data about you:
1.1.1 Your title, name, address, email address, telephone numbers, username, password, business name, payment details and such other contact details as we require. This includes information provided at the time of registering to use, and using, the App and the Services.
1.1.2 Information that you provide by filling in forms on the Access Points. This includes information provided at the time of subscribing to our Services or requesting further Services. We may also ask you for information when you report a problem with the Access Points.
1.1.3 If you contact us, we may keep a record of that correspondence.
1.2 Each time you visit the App, we will automatically collect the following information:
1.2.1 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 and the type of mobile browser you use;
1.2.2 information stored on your Device; and
1.2.3 details of your use of the App including, but not limited to, traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
1.3 When you use the App, we may use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time through the App.
1.4 You should only submit to us or the Access Points information which is accurate and not misleading. You should keep that information up-to-date and let us know if any of that information changes by emailing us at firstname.lastname@example.org. By submitting your or anyone else’s data to us or the Access Points, you must ensure that you have full authority and consent to supply us with that data on their behalf and you warrant to us that you have that authority.
1.5 We also work closely with third parties, and we will inform you when we receive information about you from them, and the purpose for which we intend to use that information.
2. IP addresses
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our user’s browsing actions and patterns, and does not identify any individual.
3.3 If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.
3.5 The Website uses the following cookies:
4. Where we store your personal data
4.1 All information you provide to us is stored on our secure servers. We use industry standard security and firewalls on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain Services, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
4.2 We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
4.3 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 the Access Points; 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.
6. Uses made of the information
6.1 We use information held about you in the following ways:
6.1.1 To ensure that content from the Access Points are presented in the most effective manner for you and for your computer or device.
6.1.2 To provide you with the Services and billing information in relation to the Services.
6.1.3 To manage the Access Points, detect fraud or Access Point abuses, send you information relevant to the Access Points and in case we have any queries.
6.1.4 To carry out our obligations arising from any contracts entered into between you and us.
6.1.5 To notify you about changes to the Services.
6.1.6 To provide you with information about other services we offer that are similar to those that you have already purchased or enquired about.
6.1.7 To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the [order form OR registration form]).
6.1.8 To administer the Access Points and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
6.1.9 As part of our efforts to keep the Access Points safe and secure.
6.1.10 To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
6.1.11 To allow you to register for an account on the Access Points, which may include sending an email to you to confirm your details.
6.1.12 To give you a new password if you have forgotten it.
6.2 We also need to use your contact details and other information for any aspect of the Access Points (including, without limitation, providing customer support, preventing or investigating prohibited activity, enforcing the EULA, and verifying information).
6.3 We may transfer our databases containing your personal information if we sell our business or part of it to an actual or potential purchaser.
6.4 We may also disclose your details as described elsewhere in this Privacy and Cookies Policy.
6.5 You agree that we have the right to share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, and selected third parties including:
6.5.1 business partners, suppliers and sub-contractors for the performance of any contract we enter into with you or them, or that you enter into with them;
6.5.2 analytics and search engine providers that assist us in the improvement and optimisation of the Access Points;
6.5.3 in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
6.5.4 if Skiffl Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
6.5.5 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.6 Other than as set out in this Privacy and Cookies Policy, we shall NOT sell or disclose your personal data to third parties without obtaining your prior consent unless this is necessary for the purposes set out in this Privacy and Cookies Policy or unless we are required to do so by law.
7. Your rights
7.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
7.2 The Access Points may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
8. 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. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
9.1 By submitting data to us and using any Access Point, you consent to our use of your data and of anyone you represent in the manner set out in this Privacy and Cookies Policy (as amended from time to time, as described below) and you are responsible for ensuring that you have authority to consent on behalf of anyone about whom you submit data to us.
9.2 Please note that you can revoke any consent you have given us under this policy at any time by contacting us on firstname.lastname@example.org, and referencing this Privacy and Cookies Policy in the email subject line, using the body of the email to say what consent you are revoking.
10. Changes to our Privacy and Cookies Policy
Any changes we may make to this Privacy and Cookies Policy in the future will be posted on the Access Points and, where appropriate, notified to you by e-mail. Each time you enter an Access Point, you agree that the Privacy and Cookies Policy current at that time shall apply to all information held by you.
Questions, comments and requests regarding this Privacy and Cookies Policy are welcomed and should be addressed to Skiffl Ltd, 26 Greek Street, Stockport, Cheshire, SK3 8AB. This Privacy and Cookies Policy was most recently updated in April 2017.