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Privacy Policy

PRIVACY POLICY
Last updated July 2022.
This privacy relates to your use of our ‘Pinpoint Eye’ mobile application software and all data we supply with the software and any updates or supplements to it (the “app”), together with the services you connect to and the content we provide to you through the app (“service”). For further information about the app and our service, you should read our terms and conditions available at www.pinpointeye.com. This policy and the terms and conditions will govern your use of the app and the service at all times. 

Your privacy is important to us. This policy sets out information on the personal data we collect about you, and your rights in respect of that data. 
Pinpoint Eye is owned and operated by Insight Business Applications Limited, a company registered in England and Wales under company number; 3208074, with its registered office at 2 Verwood Drive, Bitton, Bristol, South Gloucestershire, BS30 6JP (“we” or “us”).
About us

We will only process your personal data in line with data protection laws, namely the retained EU law version of the General Data Protection Regulation (2016/679), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directives) Regulations 2023. If any of these laws are replaced or superseded, we will also comply with those.

We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB338687. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You can reach us at dougobiz10@gmail.com.

Our data protection officer (DPO) is Douglas MacDonald and his details are: 

0117 9324495 
dougobiz10@gmail.com

What we may collect

Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you when you engage with us. Whenever we collect personal data about you, we must have a legal ground (lawful basis) to do so. We must also observe the principles of data minimisation and only collect as much personal data as necessary and retain that data for no longer than necessary.


Type of data
Purpose and Lawful Basis

Identity and contact information you provide to us when contact us (Contact Data and Identity Data)
Includes: 
    • Name
    • Email address
    • Telephone number
We collect this information so we can respond to your enquiry or correspondence. We might use your name and email address to send you information about your matter or issue raised and we may also provide you with updates on changes to this policy or security information. 

The lawful basis for collection of this information is it is needed to perform our contract with you (i.e., to respond to your enquiry), it is in our legitimate interest (i.e., to respond to contact requests), and you have consented (i.e., by requesting that we contact you).
Identity and contact information you provide to us when you create an account on the app and when you subscribe to the app
(Contact Data and Identity Data)
Includes:
    • Name
    • Email address
    • Phone number
    • Gender
    • Address

We require this information so that you can create an account on the app.

The lawful basis for collection of this information is it is needed to perform our contract with you (i.e., to enable you to create an account on the app), it is in our legitimate interest (i.e., to enable persons to access our services), and you have consented (i.e., by choosing to provide us with the requested information).

Please note that payments are processed by Stripe and we neither see nor store your payment method.
Location data you provide when you choose to share your location with others (Location Data)
Important

For full information on the collection and processing of your location data, please refer to the ‘Location data’ section below.

Contact information you provide to us when you choose to import your contacts into the app
(Contact and Identity Data)
Includes:
    • Name
    • Email address
    • Phone number
    • Gender
    • Address

We require this information so that you can use the services offered by the app and import your contacts into the app.

The lawful basis for collection of this information is it is needed to perform our contract with you (i.e., to enable you to use the services offered by the app), it is in our legitimate interest (i.e., to enable you full access to the services of the app), and you have consented (i.e., by choosing to provide us with the requested information).

You should obtain the consent of your contacts before importing their contact information into the app. By importing the contact information into the app, you warrant you have this consent.
Usage and log data
Includes: 
    • Information about your activity on the app
    • Your services settings
    • The time, frequency and duration of your use of the app
    • Log files, diagnostic and performance logs and reports.
This data is automatically collected when you use the app. The purpose is to enable your access to the app and so that we may monitor usage and performance information. 

The lawful basis is it is necessary for us to perform our contract with you (i.e., to give you access to the service our app provides) and it is in our legitimate interest to monitor access and issues relating to performance. 
Device and connection information
Includes:
    • Hardware model
    • operating system information
    • battery level
    • signal strength
    • app version
    • mobile network, connection information (including phone number, mobile operator or ISP)
    • language and time zone, IP address, device operations information
This data is automatically collected when you use the app or the services. The purpose is to enable your access to the app and the services. 

The lawful basis is this is necessary for us to perform our contract with you (i.e., to give you access to the app and our services).


Location data

Location data is defined as information collected by a network or service about where the user’s phone or other device is or was located – for example, tracing the location of a mobile phone from data collected by base stations on a mobile phone network. Within this policy, where we refer to your personal data or personal information, this includes the location data outlined in this section.

We are permitted to collect your location data as we are a provider of a value-added service, we have your consent to the use of your location data for the value-added service, and our processing of your location data is necessary for that purpose.  By downloading the app and using the services, you are consenting to our collection and processing of your location data. 

The type of location data we collect and process is your exact physical location and coordinates. 

We will use the location data you choose to provide to us so that you can share your location with others, thereby enabling you to make use of the services the app provides. 

The lawful basis for collection of this information is it is needed to perform our contract with you (i.e., to enable you to use the services offered by the app), it is in our legitimate interest (i.e., collect and sharing your location data is the purpose of the app), and you have consented (i.e., by choosing to provide us with the requested information).

We will retain your location data for as long as you choose to share it with another. When location sharing is stopped, either by you or by the app, we no longer hold the location data and when you delete a saved place, the location data will be automatically and permanently deleted from the app. 

Your location data will only be shared with those persons you choose to share your location with, and we will not share your location with anyone else. You may withdraw your consent to the sharing of your location data when you cease your use of this feature of the app and you delete any saved location in the app.

Storing your personal data

We store all of your personal data on our servers within the UK. We may transfer your collected data to storage outside the European Economic Area (EEA) or the UK, or it may be processed outside the EEA or the UK so you can receive our services. If we do store or transfer data outside the EEA or the UK, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA or the UK. This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA or the UK.

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through the app or services. 

Specifically, we use Google Cloud services to host all personal data collected. Google’s cloud services employ industry standard security including encryption in transit and at rest and ISO/IEC27001/27017/27018/27701, SOC 1/2/3, PCI DSS, and FedRAMP certifications. For more information, please refer to: https://cloud.google.com/security/. It is important to note that personal data is encrypted between your device and any external host storage we use.

Disclosing your personal data

We may disclose your information in the following cases:

    • If we want to sell our business, or our company, we can disclose it to the potential buyer
    • We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
    • We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
    • We can exchange information with others to protect against fraud or credit risks.

We might contract with third parties/subcontractors to supply our services to you on our behalf.  If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described in this policy.

Your rights

When you provide us with personal data, you have certain legal rights, and these include:

    • To request access to, deletion or correction of, your personal data held by us at no cost to you
    • To request that your personal data be transferred to another person (data portability)
    • To be informed of what data processing is taking place
    • To restrict processing
    • To object to processing of your personal data
    • To complain to a supervisory authority.

We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to. If you wish to access, rectify, erase, or transfer your personal data, please contact us at info@pinpointeye.com.

Third party links

This policy only relates to the app and our services. We might have links on/within the app and our services to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites. 

Changes to this policy

We can update this policy from time to time as laws change or as our services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.