‘ROUND Order and Pay App’ Mobile Application
Last updated: 16/06/2020
SCOPE OF POLICY 1
WHAT INFORMATION DO WE PROCESS? 2
PURPOSES AND BASES FOR PROCESSING YOUR DATA 3
SHARING YOUR INFORMATION 4
INTERNATIONAL TRANSFERS 5
DATA RETENTION PERIOD 5
SECURITY OF PROCESSING 5
YOUR RIGHTS 6
ROUND APP LTD (“ROUND/we/us/our”) of 37 2nd & 3rd Floor, Ship Street, Brighton, East Sussex, England, BN1 1AB is committed to protecting and respecting your privacy in line with the data protection principles set out in the European Union General Data Protection Regulation 2016 (“GDPR”) and the Data Protection Act (2018).
This privacy notice explains what personal data ROUND collects from individuals (“you/your”) who use our ‘ROUND Order and Pay App’ (“App”) mobile application and visit the ROUND website, or who contact us using our web forms, by email, phone or through one of our social channels, or subscribe to one of our marketing communications. Please read the following carefully to understand our practices regarding your personal data and how we process it.
SCOPE OF POLICY
the ROUND Order and Pay mobile application software once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”).
Any of the services accessible through the App (“Services”)
As an information-led business, we place great importance on ensuring the quality, confidentiality, integrity and availability of the data we hold and in meeting our data protection obligations when processing personal data. ROUND is committed to protecting the security of your personal data. We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use or disclosure.
We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.
WHAT INFORMATION DO WE PROCESS?
Information you provide to us
We process information you give us, either through the use of the App, forms on our website (https://round.app) or by corresponding with us by telephone, email or otherwise. This includes information you provide when you register to use our App, subscribe to a service, search for a product or service, participate in discussion boards or other social media functions linked to our site, or when you report a problem with our App or site.
Information processed when creating an App account
When submitting a new account application on the App, or by corresponding with us we process the following information to set up your account:
Your mobile phone number
Your email address
Your date of birth (for age verification purposes)
Unique application number: when you install or uninstall our App a unique ID is assigned to your device. This ID and information about your installation, for example, the type of operating system, may be sent to us.
For business customers, we may record additional details about you from public information sources, such as LinkedIn, banks, credit reference agencies, and public registers, such as Companies House.
Information processed when using the App and Services
We process the following information when you use the App or Services:
Location information. We use GPS technology to determine your current location. Our location-enabled Services require your location data for the App to work. You will be asked to for your consent to your data being used for this purpose.
Your order history
When you report a problem with the App
Unique application number checks to provide automatic App and Services updates
Information we receive from other sources (Third Party Information).
We work with third party business partners who provide technical, payment and delivery services and may receive information about you from them which may include your email address and PayPal username and payment method.
Pixels & Web Links
ROUND uses pixels on our website. These are small graphic images. They are downloaded to your device when you visit a website unless you have set your browser to reject them.
We use these to remember your preferences, display content that is more relevant to you and improve your overall experience of our site. We use pixels to track the actions of individuals and measure the success and response rates of our marketing campaigns.
Our website contains links to other websites. This privacy notice only applies to this website, so please read the privacy notices provided by the other websites.
PURPOSES AND BASES FOR PROCESSING YOUR DATA
We may use your data for the following purposes and on the following lawful bases:
Lawful Bases for Processing
Responding to communications from you.
It is in our legitimate interest to respond to enquiries made via our App, website, by email, through our social channels or any other means.
Sending you information on our loyalty programme and other ROUND news, features and information which may be of interest.
When you agree to be contacted for marketing, we will rely on your consent, which may be withdrawn at any time by emailing email@example.com.
Fulfilment of our service obligations, as set out in our Terms and Conditions (order confirmation, payment processing, recording your order history, and App personalisation).
This is necessary for the performance of the contract we have entered with you.
Recording your location using GPS tracking to locate the nearest venue and for route planning.
This is necessary for the performance of the contract we have entered with you.
Business management, forecasting and statistical purposes.
It is our legitimate interest to analyse App and Service usage, manage our relationship, develop new products and services, and for managing our business.
Improving our App, our Services, website, and the overall customers experience.
It is our legitimate interest to perform data analytics to help improve our App and Services and review search engine data to optimise our website.
Improving our website and the overall website visitor and user experience.
We use pixels on our website with your consent.
SHARING YOUR INFORMATION
For our own legitimate business interests, we may share your information with the following categories of third parties:
Debt collection agencies for the purposes of collecting any arrears.
If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
If ROUND APP LTD or substantially all of its assets are acquired by a third party, personal data held by it about our customers will be one of the transferred assets.
We may share your information if we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation or request. For example:
To protect the rights, property, or safety of ROUND APP LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we use third parties established in third countries outside the EEA to process your data we will ensure that we protect your privacy and your rights using the European Commission’s Standard Contractual Clauses (SCC) for the transfer of personal data to data processors. More information about SCC is available here.
DATA RETENTION PERIOD
We will retain your personal data for as long as it necessary for the purpose of our relationship or until you object to us processing it or withdraw your consent.
SECURITY OF PROCESSING
All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The GDPR provides you with certain rights in relation to the processing of your personal data, including to:
Request access to personal data about you (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.
Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request personal data provided by you to be transferred in machine-readable format (“data portability”).
Request erasure of 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 personal data where you have exercised your right to object to processing.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it).
Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on the legitimate interests of ROUND.
These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at firstname.lastname@example.org or by writing to us, see ‘Contact’ below.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.
You can contact ROUND in relation to data protection and this privacy notice by writing to:
Data Protection Manager,
ROUND APP LTD,
37 2nd & 3rd Floor,
Alternatively, you can email us at email@example.com