UNIFY GIVING LTD
UNIFY MOBILE APPLICATION PRIVACY POLICY
Last Updated:
CONSENT TO INSTALLATION OF THE APP
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 Policy (the “Policy”) and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this Policy:
- YES – I consent to the installation of the App for the purposes of donating money to the homeless community.
- NO – I do not consent to the installation of the App.
HOW YOU CAN WITHDRAW CONSENT
Once you provide consent by selecting ‘YES’, you may change your mind and withdraw consent at any time by contacting us via the details provided in this Policy but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
CONSENT TO PROCESSING LOCATION DATA
- YES – I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated to enable me to donate to local homeless people or the homeless community in a specified area).
- NO – I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
***
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 Unify (the “App”) is provided by Unify Giving Ltd (the “Company”, “Unify”, “we”, “our” or “us”), a private company limited by shares registered in England with registered address at 2 Naseby Close, Pontprennau, Cardiff, Wales, CF23 8LS and registered company number 13393372.
1.2. We take your privacy very seriously. Please read this Policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you.
1.3. It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event that you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the United Kingdom General Data Protection Regulation (the “UK GDPR”).
1.4 We are the controller of your information obtained via the App, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
1.5. The App is not intended for children and we do not knowingly collect data relating to children.
2. WHAT THIS POLICY APPLIES TO
2.1. This Policy relates to your use of:
a. the App, once you have downloaded a copy to a mobile device or computer; and
b. the service you connect to via the App and the content we provide to you through it including, without limitation, the provision of:
i. an online contactless donation system enabling users to donate to individuals within the homeless community directly onto RFID wristbands issued by us to those individuals, which they can use to purchase essential goods through a restricted payment card; and
ii. a Unify Sofa-Giving feature allowing users to donate through the App from the comfort of their own homes (“Unify Sofa-Giving”), (together, the “Services”).
2.2. The App may link to other apps, websites or services owned and operated by third parties including certain trusted partners such as Manigo and relevant charity partners to provide additional products, information and services to you. These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their own privacy policies as appropriate.
2.3 This Policy should be read alongside our terms and conditions which can be located at the bottom of the App or by clicking here (the “Terms”).
3. INFORMATION WE COLLECT ABOUT YOU
3.1. The information we collect about you depends on the particular activities carried out through the App. We will collect and use the following information about you:
| How data is collected | Categories of data |
| Identity and account data you input into the App. |
|
| Data collected when you use specific functions in the App. |
|
| Data collected when you permit its collection. |
|
| Other data the App collects automatically when you use it. |
|
| Data collected when you make a payment through our payment services provider. |
|
3.2 If you do not provide the information we ask for where it is indicated to be ‘required’ at the point of collection, it will delay or prevent the App from providing Services and functions to you as explained in the relevant forms on which such data is collected.
3.3 We collect and use your information for the purposes described in ‘How and why we use your information’ below.
3.4. We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
3.5 We do not collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).
4. LOCATION SERVICES/DATA
4.1. The App will request your consent to use location services to precisely identify your location each session (namely each time the App is opened or has been placed in the background for more than thirty (30) seconds. We require access to that data in order to identify real world locations of homeless individuals near you or in a specific location to enable you to donate via Unify Sofa-Giving.
4.2 If you do not provide your consent, you may use the App to donate to local homeless individuals using the RFID wristbands payment capability, but Unify Sofa-Giving will not be available. To withdraw your consent at any time, please contact us (see ‘How to contact us’ below) and disable the location data/services on your mobile device (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn).
4.3. We will not process your location data other than as strictly required to enable Unify Sofa-Giving.
4.4. The location services in the App will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by disabling the location services on your mobile device. When you allow your device to use location services/data, data will also be collected by the organisations providing the device operating system in accordance with their own privacy policies.
5. HOW YOUR INFORMATION IS COLLECTED
We will collect and process the following data about you:
a. Information you give us: This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by completing forms on the App or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you search for or download the App, register to use the App, subscribe to any of our Services, make an in-App donation, share data via the App’s social media functions, enter a promotion or survey, and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence (see ‘How to contact us’ below).
b. Information we collect about you and your device: Each time you visit the App, we may automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies (see ‘Cookies’ below).
c. Location Data: We also use GPS technology to determine your current location. Some of our location-enabled services (including Unify Sofa-Giving) 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 by disabling Location Data in your settings.
d. Information we receive from other sources including third parties and publicly available sources: We will receive personal data about you from various third parties as set out below:
i. Device Data: from analytics providers such as Google and Facebook, advertising networks such as Google and Facebook and search information providers such as Google and Facebook;
ii. Contact, Financial and Transaction Data: from providers of technical, payment and delivery services such as Manigo; and
iii. Identity and Contact Data: from data brokers or aggregators such as Facebook, Instagram and Gmail.
6. COOKIES
We use cookies and/or other tracking technologies to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy.
7. HOW AND WHY WE USE YOUR INFORMATION
7.1 Under data protection law, we can only use your information when the law allows us to do so, for example:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
7.2 We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.
7.3 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
7.4 The table below explains what we use your information for and why:
| What we use your information for | Type of Data | Lawful basis for processing |
| To install the App, register you as a new App user and manage your account with us. | Identity Contact Financial Device |
|
| Providing Services and/or the functionalities of the App to you. | Identity Contact Financial Transaction Device Marketing & Communications Location |
|
| To process -App donations and deliver Services including managing payments and collecting money owed to us. | Identity Contact Financial Transaction Device Marketing & Communications Location |
|
| Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us. | Identity Contact Financial Transaction Device |
|
| To manage our relationship with you including notifying you of changes to the App or any Services. | Identity Contact Financial Profile Marketing & Communications |
|
| To enable you to participate in a promotion or complete a survey. | Identity Contact Device Profile Marketing & Communications |
|
| To administer and protect our business and the App including troubleshooting, data analysis, system testing and to protect the security of systems. | Identity Contact Device |
|
| To enforce legal rights or defend or undertake legal proceedings. | Identity Contact Device Content Profile Usage |
|
To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve the App. Statistical analysis to help us understand our users. | Identity Contact Device Content Profile Usage Marketing & Communications Location |
|
| Marketing our Services to existing and former users. | Identity Contact Device Content Profile Usage Marketing and Communications Location |
|
8. MARKETING
8.1. We will use your information to send you updates by email about our Services, including exclusive offers, promotions or new services.
8.2. We have a legitimate interest in using your information for marketing purposes (see above ‘How and why we use your information’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
8.3. You have the right to opt out of receiving marketing communications at any time by:
- contacting us (see ‘How to contact us’ below);
- using the ‘UNSUBSCRIBE’ link in e-mails or
- updating your marketing preferences on your account by navigating to your settings.
8.4. We will always treat your information with the utmost respect and never sell it with other organisations for marketing purposes.
8.5. For more information on your right to object at any time to your information being used for marketing purposes, see ‘Your legal rights’ below.
9. WHO WE SHARE YOUR INFORMATION WITH
9.1 We routinely share your information with:
- service and analytics providers acting as processors who we use to help us run our business or provide the Services or functionalities in the App, DigitalOcean and in particular marketing agencies or hosts of the systems that deliver the App’s functionalities including data analysts to identify any anomalies such as suspected money laundering;
- Apple Store, Google Play where you permit us to collect location data as described in ‘Location services/data’ above. For further information on how Apple Store, Google Play to protect your information, see ‘Location services/data’ above;
- our trusted Donor Rewards partners (as defined in the Terms) from time to time, details of whom can be found on our website or the App;
- our business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you;
- advertisers and advertising networks such as Google and Facebook that require the data to select and serve relevant adverts to you and others. We do not disclose Identity Information about users to our advertisers, but we may provide them with aggregated information or anonymised data about our users. We may also use such aggregated information or anonymised data to help advertisers reach the kind of audience they want to target. We may make use of personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
- search engine providers such as Google that assist us in the improvement and optimisation of the App.
9.2 We only allow the companies referred to above to handle your information if we are satisfied they take appropriate measures to protect your information. 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.
9.3 We or the third parties mentioned above occasionally also need to share your information with certain recipients who will be bound by confidentiality obligations as follows:
- our or their external auditors;
- our or their professional advisors (such as lawyers and other advisors);
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations; and
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. Usually, information will be anonymised but this may not always be possible.
9.4 If you would like more information about who we share your information with and why, please contact us (see ‘How to contact us’ below).
10. HOW LONG YOUR INFORMATION WILL BE KEPT
10.1 By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease using our services.
10.2 In some circumstances you can ask us to delete your data (see ‘Your legal rights’ below).
10.3 In some circumstances we will 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.
10.4 In the event that you do not use the App for a period of one hundred and eighty (180) days, then we will treat the account as expired and your personal data may be deleted.
11. INTERNATIONAL TRANSFERS
11.1 Some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the United Kingdom.
11.2 Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one (1) of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
- where we use certain service providers, we may use specific contracts approved by the United Kingdom which give personal data the same protection it has in the United Kingdom.
11.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom (see ‘How to contact us’ below).
12. YOUR LEGAL RIGHTS
12.1 You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your information. | The right to be provided with a copy of your information. This is commonly known as a “data subject access request” and enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. |
| Correction (also known as rectification). | The right to require us to correct any mistakes in your information. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. |
| Erasure (also known as the right to be forgotten). | The right to require us to delete your information in certain situations. 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 information unlawfully or where we are required to erase your personal data to comply with local law. 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. |
| Restriction of processing. | The right to require us to restrict use of your information in certain circumstances. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
|
| Data portability. | The right to 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. |
| To object to use. | The right to 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
| Not to be subject to decisions without human involvement. | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by the App. |
| The right to withdraw consent. | If you have provided us with a consent to use your information, you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us (see ‘How to contact us’ below). Withdrawing consent will not affect the lawfulness of our use of your information in reliance on that consent before it was withdrawn. 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. |
12.2 For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the United Kingdom’s Information Commissioner (the “ICO”) (https://ico.org.uk/your-data-matters/) on your rights under the UK GDPR.
12.3 If you would like to exercise any of those rights, please contact us (see ‘How to contact us’ below). When contacting us please:
- provide enough information to identify yourself (for example, your full name, address and account number) and any additional identity information we may reasonably request from you; and
- let us know which right(s) you want to exercise and the information to which your request relates.
13. KEEPING YOUR INFORMATION SECURE
13.1 We have appropriate security measures to try to prevent your information from being accidentally lost, or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it.
13.2 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 using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
13.3 We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.
13.4 Certain Services include social networking, or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
13.5 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
13.6 If you want detailed guidance from Get Safe Online on how to protect your information and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. . Get Safe Online is supported by HM Government and leading businesses.
14. HOW TO COMPLAIN
14.1 Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
14.2 You also have the right to lodge a complaint with the ICO using the details at https://ico.org.uk/make-a-complaint or via telephone: 0303 123 1113.
15. CHANGES TO THIS POLICY
15.1 We may change this Policy from time to time. When we make significant changes we will take steps to inform you, for example via the App or by other means, such as e-mail .
15.2 The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
15.3 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
16. HOW TO CONTACT US
16.1 You can contact us and/or our Data Privacy Manager by post, e-mail or telephone if you have any questions about this Policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
16.2 Our contact details are shown below:
| Our contact details | Our Data Privacy Manager contact details |
E-mail address: contact@unifygiving.com Postal address: 2 Naseby Close, Pontprennau, Cardiff, Wales, CF23 8LS Telephone number: +447775 863332 | E-mail address: contact@unifygiving.com Postal address: 2 Naseby Close, Pontprennau, Cardiff, Wales, CF23 8LS Telephone number: +447775 863332 |
17. DO YOU NEED EXTRA HELP?
If you would like this Policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).