How To Make Limited
This notice applies to your use of:
The “App” (the How To Make mobile app, including the app software, all data and content provided through the app and all updates), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”).
The services available within the App (“Services”). 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. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This privacy notice is in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the notice here:App privacy notice (final)_10897551_1
WHO WE ARE
How To Make Limited (“we”, “us”, “our”) is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. You will find our contact details at the end of this notice (see: “How to contact us”).
PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is any information relating to an identified or identifiable individual.
We collect, use, store and transfer different kinds of personal data about you. This may include:
User name or similar identifier;
Date of birth;
Telephone numbers (mobile and landline);
Passport or driving licence (for the ‘Get Verified’ function);
Data about your Device, including the type of mobile Device you use, any unique 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), your mobile operating system, the type of mobile browser you use, time zone setting and other technology on the Device you use to access the App;
Information stored on your Device, including friends’ lists, login information and photos, videos or other digital content;
Information about how you use the App, including, but not limited to traffic data and other communication data, and the resources that you access;
Marketing and communications information, including your preferences in receiving marketing from us and our third parties and your communication preferences; and
Information that you volunteer to us when you download or register to use the App, subscribe to any of our Services, share data via the App’s social media functions, fill in forms on the App, use the direct message function on the App, report a problem with the App or our Services and when you correspond with us by telephone, email, chat or otherwise.
If you do not provide personal data
If you do not provide the personal data we ask for, this may delay or prevent you from accessing the App or functions on the App.
HOW YOUR PERSONAL DATA IS COLLECTED
Depending on the circumstances, we use different methods to collect personal data from and about you including:
Directly from you. You may give us your personal data by registering to use the App, subscribing to any of our Services, sharing data via the App’s social media functions, filling in forms on the App, using the direct message function on the App, reporting a problem with the App or our Services or by corresponding with us by telephone, email, chat or otherwise.
Via the App store. We may receive some personal data about you when you download the App.
Automated technologies or interactions. Each time you use the App we will automatically collect personal data including data about your Device, information stored on your Device and information about how you use the App.
From your Device. Depending on your content creation, the App may require access to your camera and photographs. To retrieve existing photographs, the App will need access to your Device’s storage. You will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time via the settings on your Device.
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:
to comply with our legal obligations;
for the performance of our contract with you or to take steps at your request before entering into a contract;
for our legitimate interests or those of a third party; or
where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and our lawful basis for doing so.
What we use your personal data for
Our lawful basis for processing data
To install the App and register you as a new App user
With your consent
To deliver our Services
With your consent
Necessary for the performance of our contract with you or to take steps at your request before entering into a contract
To manage our relationship with you which will include notifying you about changes to the App or any Services, changes to our terms of business or privacy notice or dealing with complaints
Necessary for the performance of our contract with you
Necessary to comply with our legal obligations
Necessary for our legitimate interests or those of a third party e.g. to keep records updated and to analyse how customers use our Services
To administer and protect our business and the App including troubleshooting, data analysis and system testing
Necessary for our legitimate interests or those of a third party e.g. for running our business, provision of administration and IT service and network security
To deliver content and advertisements to you
To make recommendations to you about products 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
Necessary for our legitimate interests i.e. to develop our Services and grow our business
For push notifications – with your consent
Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please telephone, email or write to us (see: “How to contact us”).
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
We may use your personal data to send you periodic communications by email and text about our Services and events that might be of interest to you.
We have a legitimate interest in processing your personal data for marketing purposes (see “How and why we use your personal data”). This means we do not usually need your consent to send you information about our Services and events. However, where consent is needed, we will ask for this consent separately and clearly. For example, we will ask for your consent to receive push notifications.
You have the right to opt out of receiving marketing communications at any time by:
writing to us at Winchester Hill Business Park, Winchester Hill, Romsey, Hampshire, SO517ND;
calling us on 01794 339899; or
using the ‘unsubscribe’ link in our emails.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Third party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
Depending on the circumstances, we may share your personal data with:
External service providers who we use to help run our business e.g. email service provider, marketing service provider and IT and system administration service providers;
Professional advisers including lawyers, loss adjusters, insurers, auditors, technical consultants and experts; and
Other users of the App.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.
TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE UK
Some of organisations with whom we share your personal data are based outside the UK so their processing of your personal data will involve a transfer outside of the UK.
These transfers are subject to special rules under UK data protection law.
Some countries have been assessed as providing an adequate level of protection for personal data. Other countries are not considered to have sufficient data protection laws. We will, however, ensure the transfer complies with UK data protection law. We will do this by ensuring one of the following (or one of the other grounds set out in UK data protection law) applies:
your data is transferred to countries that have been deemed to provide an adequate level of protection for personal data;
the transfer is necessary for the performance of a contract between you and us;
the transfer is necessary to establish, exercise or defend legal claims;
there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of approved contractual terms); or
you have provided explicit consent to the proposed transfer after being informed of any potential risks.
Please contact us (see: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
Data protection law gives you certain rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your data:
The right to be provided with a copy of your personal data
The right to require us to correct any mistakes in your personal data
To be forgotten
In certain situations, the right to require us to delete your personal data
Restriction of processing
In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data
In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation
The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests
We do not use personal data for automated decision making.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the UK General Data Protection Regulation.
If you would like to exercise any of those rights, please email, write or telephone us (see: “How to contact us”) and let us have enough information to identify you e.g. your name and email address as well as what right you want to exercise and the personal data to which your request relates.
HOW LONG WE KEEP YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including;
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law to comply with our legal obligations.
We will not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.
In the event that you do not use the App for a period then we will treat the account as expired and your personal data may be deleted.
KEEPING YOUR PERSONAL DATA SECURE
We have put in place reasonable and appropriate security measures to endeavour to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
All information you provide to us is stored on secure servers. 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.
Once we have received your information, we will use strict procedures and security features to try and prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML4) and other technology.
Certain Services include social networking, chat room 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.
Please be aware that internet transmissions are never completely private or secure and that any message or information you send using the App or any Service may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.
The App or any Service may contain links to other independent websites which are not provided by us. Such independent sites are not under our control, and we are not responsible for and have not checked and approved their content or their privacy notices (if any).
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.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email or write to us (see: “How to contact us”). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the Information Commissioner’s Office (“ICO”) or a competent supervisory authority of an EU member state if the App is downloaded outside the UK. Further information about how to make a complaint to the ICO can be found on the ICO website www.ico.org.uk.
CHANGES TO THIS PRIVACY NOTICE
We may change this privacy notice from time to time and when we do, these changes will be posted on this page and, where appropriate, notified to you by SMS or email or when you next start the App. The new privacy notice 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.
CHANGES TO YOUR PERSONAL DATA
It is important that the personal data we hold about you is accurate and current.
Please let us know if you change your name, e-mail address or any other personal detail during our relationship with you (see: “How to contact us”).
HOW TO CONTACT US
If you have any queries about this privacy notice or how we use your personal data, you can contact us by email, post or telephone as follows:
How To Make Limited
Alexandra House, Winchester Hill Business Park, Winchester Hill Romsey, SO517ND
Do you need extra help?
If you would like this notice in another format (for example large print) please contact us (see: “How to contact us”).