App Privacy Notice
This App Privacy Notice was last modified on 07/04/2022.
Econform Limited (“Econform”, “we”) are committed to protecting and respecting your privacy.
This privacy notice will provide you information about how we look after your personal data when you use the Econform mobile application software (the “App”) and tell you about your privacy rights and how the law protects you.
1. Consent to installation of the App
- 1.1. Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this privacy notice and it is important that you read that information.
- 1.2. Before logging in to your user account via the App, you will be asked to indicate your consent to our processing of your personal data as described in our privacy notice. If you do not consent, you should not proceed with logging into the App. We will not collect any personal data through the App unless you log in via your user account.
- 1.3. You can change your mind. You may change your mind at any time to our processing of your personal data, and withdraw your consent, by ceasing to use the App or contacting us by email at email@example.com. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
2. About this privacy notice
- The App, available on the Apple app store and Google Play (the “App Site”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”).
- 2.2. This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
- 2.3. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements those other notices and is not intended to override them.
- 2.4. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
3. About us
- 3.1. For the purpose of UK data protection laws, Econform Limited is the controller and is therefore responsible for your personal data. If you have any questions, including any requests to exercise your legal rights, please contact us using the details set out below.
- 3.2. Our full contact details are:
Company name: Econform Limited
Company number: SC593489
Registered office: The Whisky Bond, 2 Dawson Road, Glasgow, Scotland, G4 9SS
4. Changes to this privacy notice
Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
5. How we collect personal data
- 5.1. Personal data means any information about an individual from which that person can be identified. It does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).
- 5.2. We may collect and process the following data about you:
- a. Information you give us (“Submitted Information”): This is personal data you give us whilst using the App. It includes information you provide when you use our Services and when you report a problem with the App, our Services, or any of our sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, e-mail address, phone number, the Device’s phone number, username, password and other registration information.
- b. Information we receive from other sources (“Third Party Information”):
- Your employer (or client/customer, if you are a contractor) will have provided us with certain personal data in order to create your user account (namely, name, email address, password);
- We use Sentry.io to help us monitor the App’s performance and deal with issues and/or crashes. In providing this service, including providing us with crash logs and performance logs, Sentry.io collects and provides to us the following personal data: the type of mobile device, your user name (email address), the name of the device you use, a unique device identifier, the device operating system and version (“Log Information”).
- c. Information we collect about you and your device (automated information): Each time you use our App we will automatically collect the following information:
- information stored on your Device, including contact information (name and email address), login information (username), access to your device image gallery (where you have allowed such access) (“Content Information”).
6. Cookies and similar technologies
- 6.1. We use login authentication tokens to authenticate you as a user of the App and distinguish you from other users of the App.
7. How we use your personal data
- 7.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- a. To provide you with access to the App and the Services.
- b. Where you have consented before the processing.
- c. Where we need to perform a contract we are about to enter or have entered with your employer (or, if you are a contractor, your client/customer). This includes the Software Terms and Conditions.
- d. 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.
- e. To deal with and/or respond to any enquiry or request made by you.
- a. Where we need to comply with a legal or regulatory obligation, including the prevention of crime.
- 7.2. In addition, we will use your personal data for the following activities:
- a. Submitted Information:
- To manage our relationship with you as a user of the App, including for the purpose of providing you with continued access to the App and Services.
- b. Third Party Information:
- To register you as a user of the App.
- Log information: monitoring crash logs and performance logs, and fixing issues.
- c. Content Information: providing you with access to the App and Services.
- a. Submitted Information:
- 7.3. may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this privacy notice for as long as it is combined.
- 7.4. Where we process personal data on the basis of consent, this means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
- 7.5. Where we process personal data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- 7.6. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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.
- 7.7. note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- 7.8. Your personal data will not be used for the purposes of automated decision-making.
8. Disclosure of your information
- 8.1. personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:
- a. Your personal data will be shared with your employer (or, if you are a contractor, your client/customer) to the extent necessary to provide you with access to the App and the Services, and where it is necessary for the performance of our contract with your employer/client/customer (as the case may be).
- b. In order to enforce the terms of our Software Terms and Conditions and other agreements or to investigate potential breaches.
- c. Where we are under a legal duty to do so in order to comply with any legal or regulatory obligation or request.
- d. On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, such as IT/website/system administration support.
- e. In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with our professional advisers and with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
- f. 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.
- g. If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about users of the App will be one of the transferred assets.
- 8.2. We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9. Where we store your personal data
- 9.1. We do not transfer your personal data outside the United Kingdom. Our servers (hosted by Amazon Web Services) are located in the United Kingdom.
- 9.2. All information you provide to us is stored on our secure servers (hosted by Amazon Web Services). Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- 9.3. 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 App; 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.
- 9.4. We will collect and store personal data on your Device using Redux with Asyncstorage.
10. Data retention
- 10.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- 10.2. To determine the appropriate retention period for personal data, 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, and the applicable legal requirements.
- 10.3. In some circumstances, you can ask us to delete your data: see section 11 below for further information.
- 10.4. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11. Your rights
- 11.1. You have the right to:
- 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 that we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
- 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 personal data unlawfully or where we are required to erase your personal data to comply with local law. Please 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.
- 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- 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.
- 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 Services to you. We will advise you if this is the case at the time you withdraw your consent.
- 11.2. If you wish to exercise any of your above rights, please send a written request to us at the postal or email address listed in section 3 above.
- 11.3. You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- 11.4. 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.
- 11.5. We try to respond to all legitimate requests within one month. Occasionally it may 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.
12. Other websites and links
- 12.1. The App may, from time to time, contain links to and from the websites of our partner networks and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services.
- 12.2. Please check third party privacy policies before you submit any personal data to these websites or use their services.
- You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.