Under data protection laws, we are required to provide you with certain information about who we are, how we process personal data and for what purposes, and your rights in relation to your personal data.
As is referred to below, it is not our intention to gather or process personal data through your use of the App although if any personal data is obtained, it will be processed in line with this Policy.
We are not liable for any mishandling of any of your personal data by Unity or Apple.
We have taken steps to ensure that we do not receive information that could be classed as personal data from either the App Store or Unity in relation to your use of the App but should we receive any personal data, it will be handled in accordance with this policy.
Please read the following carefully to understand our practices regarding any of your personal data that may come into our possession and how we will treat it.
Activated Realities Limited is the controller and is responsible for any of your personal data in its possession (referred to as Activated Realities, "we", "us" or "our" in this policy).
Our full details are:
• Full name of legal entity: Activated Realities Limited
• Title of data privacy manager: Data Privacy Manager
• Web contact available at: http://activatedrealities.co.uk/
• Postal address: International House, 12 Constance Street, London, England, E16 2DQ
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 or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
It should be noted that the App will not gather personal data and we do not intend or expect to hold any personal data.
We will receive “aggregated data” from Unity, the provider of the software with which the App was created. 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 receive information about your Usage Data (referred to below) to calculate the percentage of users accessing a specific App feature or information about countries in which the App is being downloaded.
If, for any reason, we do hold any data about you that could be classed as personal data, it may fall into the following categories (and these may be referred to throughout this policy):
• Identity Data: username or similar identifier.
• Contact Data: email address if you contact us about the App.
• Device Data: includes the type of mobile device you use.
• Usage Data: includes details of your use of the App and features used or accessed.
• Location Data: the country in which you have downloaded the App. This is limited to country and will not be, for example, city or address specific.
Even though the App is designed for use by those with visual impairments, we do not collect or process any “special categories of personal data” about you (this includes information about your health, race or ethnicity, religious or philosophical beliefs and so on) and we have no way of recording whether any user has a visual impairment or not.
Personal data, should any come into our possession, would be received as follows:
• Information you give us. This is information (including Identity and Contact Data) you consent to giving us about you by filling in forms on our website, or by corresponding with us (for example, by email. It includes information you provide if you report a problem with the App. If you contact us, we will keep a record of that correspondence.
As referred to above, we may receive aggregated data but this cannot be used to identify you. It is only if you gave us sufficient information that enabled us to be able to identify your use from within the aggregated data that that information would become personal data relating to you.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
• Where you have consented before the processing (for example where you contact us via our website).
• Where we need to perform a contract we are about to enter or have entered with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
The Glossary below can be used to find out more about the types of lawful basis that we will rely on to process your personal data.
|Purpose/activity||Type of data||Lawful basis for processing|
|To manage our relationship with you including notifying you of changes to the App or any similar or related services||
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how users use our products/ services)
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||
|Necessary for our legitimate interests (for running our business, provision of administration and IT services and security)|
Should we hold any personal data, we will not share it with any third party except for as set out below or where we may be required to by law or to assist in law enforcement.
When you consent to providing us with your personal data, we may need to share your personal data with the third parties set out below for the purposes set out in the table above:
• Service providers acting as data controllers or processors based in the United Kingdom who provide IT and App/system administration services. We may also need to share your personal data with Unity (in relation to software issues) or Apple (in relation to App operation or delivery issues) as may be appropriate.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
We do not transfer your personal data outside the European Economic Area (“EEA”).
All information that we may hold in relation to you is stored on our secure servers.
If we do hold any personal data about you, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Where we hold any personal data about you, we will not hold it for any longer than is necessary. If we hold personal data about you, we will periodically consider whether any of such information can be deleted, having regard to the reason that we hold your data. We will not hold any of your personal data for longer than 6 years.
In some circumstances you can ask us to delete your data: see under “Your legal rights” below for further information.
If we do hold your personal data, we may anonymise it (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.
Consent 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You can exercise any of these rights at any time by contacting us via our website.
In relation to any personal data that we may hold for you, 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 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 we hold about you corrected, though we may need to verify the accuracy of the new data 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 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.
• 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 information 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 functions or services to you.