Version 1.0, 9th September 2018
Size Me Up Ltd. Contact Details
Entity Name: Size Me Up Ltd.
Name or title of [DPO]: Svilen Valentine
Email address: email@example.com
Postal address: 24 Morningside Road, Edinburgh, EH10 4DA
We take the protection of your data seriously and would appreciate the chance to deal with your concerns before you approach the ICO, so please don't hesitate to contact us in the first instance.
If you are concerned because this statement is not accessible due to language or other issues, please contact us and we will try our best to make this statement accessible to you. We are committed to transparency and clarity when it comes to how we use your personal data. If there is a part of this statement that you cannot understand, please contact us and we will try our best to clarify your rights.
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.
Before use of this Web Application, you will be prompted to give us your consent to our processing of your personal data (including, for example, your name and email address) as described in this policy. You can obtain a copy of this policy by clicking here.
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 using the details at the head of this document, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
We are committed to protecting your personal data and respecting your privacy. We process certain Digital Location Data when you use the Size Me Up Mobile Application. Details about what data we collect, how and why we process it can be obtained by viewing our Cookies Policy.
- The Size Me Up Web Application hosted on https://beta.sizemeup.xyz (Application Site), once you have streamed a copy of the App onto your mobile telephone, handheld or other digital device.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Web Application is not intended for children and we do not knowingly collect data relating to children. We require parental consent prior to the use of our application for anyone under the age of 16. For more details on this, please refer to the Children section of this document
Please read the following carefully to understand our practices regarding your personal data and how we will treat it. Alternatively, you can download a pdf version of the policy here , at which point a download will begin.
Structure of this Document
This policy is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
Size Me Up is the data controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy.
We have appointed a data protection officer (DPO) which you may contact anytime if you have a question about your Privacy, Security or wish to make a request or complaint related to your data. Please contact them using the details set out below.
In order to ensure that we receive your request or complaint as soon as possible, you may put “Privacy” somewhere in the subject line of your email to us.
Entity Name: Size Me Up Ltd.
DPO: Svilen Valentine
Email Address: firstname.lastname@example.org
Address: 24 Morningside Road, Edinburgh, EH10 4DA
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 Web App is downloaded outside the UK.
This version was last updated on September 9th 2018. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you directly when you next log onto one of the Services Sites or prompt our Web App. 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 Services.
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.
Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as digital location data in the form of an IP address. Please check these policies before you submit any personal data to these websites or use these services.
2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you if you provide them to us:
- Identity Data. Your first name, your last name, photos of you, your height, your body measurements
- Contact Data. Your email address.
- Profile Data. Your username (which is also your email address), password (that you create and we do not have access to).
- Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
We explain these categories of data in the Categories of Personal Data Section 11, which can be found below.
Aggregated and Anonymized Data
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 anonymized measurements, allowing is to produce statistical data for the purpose of improving our services.
Special Categories of Data
We do not collect any Special Categories of Personal Data about you special categories include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We will collect and process the following data about you:
- Information you give us - This is information (including your first and last name, email address, height, any measurements you input, and photos of you) you consent to giving us about you by filling in forms on the Size Me Up site (https://sizemeup.xyz) and inputting your details on the Size Me Up Web Application (found at https://beta.sizemeup.xyz), or by corresponding with us (for example, by email or the feedback form on our site). It includes information you provide when you register to use the Web Application, download or register the Application, subscribe to any of our Services, search for the Application or Service, share data via the Applications's social media functions, enter a competition, promotion or survey, and when you report a problem with the Application, our Services, or any of Our Sites. If you contact us, we will also keep a record of that correspondence.
- Information we collect about you and your device - Each time you visit https://sizemeup.xyz or use the Sizemeup Web Application, we will automatically collect some personal data such as Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Cookies Policy for further details.
- 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:
- Analytics Providers - Google, whose servers are potentially based outside the EU;
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data lawfully and with your consent. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- 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.
Details about the types of lawful basis that we will rely on to process your personal data can be found in the Glossary below.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
5. DISCLOSURES OF YOUR PERSONAL DATA
We will also ask you for your consent to share your personal data with the third parties. The following describes our third-party processing. You will be notified of any changes to our Third-Party processing before being allowed to continue to use our goods and services.
External Third Parties
Purpose of Processing
Service providers Acting as processors based in the UK and within the EEA, who provide IT and system administration services, and data storage for us. Google, Facebook, and other parties may store your data on secure servers. We also use Google Analytics. Additionally, if you click on third-party links available on our Sites or Web App, we may link your account to Social Media such as Facebook, Instagram, and other social media platforms. Please refer to our policy regarding third-party links by referring to the Third Party Links section above.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK may provide consultancy, banking, legal, insurance and accounting services to us.
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.
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.
Market Researchers Based in the EEA may provide us with services relating to analysis of anonymized and aggregated data.
Fraud Prevention Agencies may be necessary for internal financial and taxation purposes. These agencies ar based within the EEA.
6. INTERNATIONAL TRANSFERS
We do not explicitly transfer your personal data outside the European Economic Area (EEA) at this time.
The only time your data will be transferred outside the EEA is where the transfer is incidental to third-party processing which is described within this Policy, such as through the use of Google Analytics whereby Google servers happen to be located outside the EEA.
In the case of any international transfer, your data will be anonymized and aggregated and is no longer considered personal data.
Any new international transfers of your data will be specified throughout our Privacy Policies and we will notify you of any changes through email or by prompting your consent again when you interact with our website, Web Application, or any other applicable service we provide to you.
7. DATA SECURITY
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 Our Sites and services by creating a profile, you are responsible for keeping this password confidential.
We ask you not to share a password with anyone. We do not have access to your password and you will have to create a new one if you lose it.
Once we have received your personal data, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.
Our services may include social networking features, such as linking your existing account to your social media platforms when you click on third-party links. 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.
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.
If you would like more information about the security of your data, please contact us using the details provided in this document.
8. DATA RETENTION
Details of retention periods for different aspects of your personal data are available below:
If you create a profile, we will store the data that you have given us until 30 days after the date on which you delete your profile or, if you request a deletion of your profile through an alternative method (such as through emailing us), your data will be deleted 30 days after the day on which we acknowledge receipt of this request. Please note that we may aggregate your measurement data and process or transfer this data. This data is anonymized, cannot be connected to you and is therefore not considered personal data.
Even where you consent to Cookies, we cannot retrieve any data that you provide during the period before you make an account and any data you have provided will be deleted after 30 days.
You can ask us to delete your data at any-time. Please refer to the Request for erasure of your personal data section below.
We may also anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 6 months, then we will treat the account as expired and inactive and your personal data you provided will be deleted after 6 months of the time in which the inactivity begins. All data will be deleted except data that has been anonymized and aggregated.
9. YOUR LEGAL RIGHTS
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 using the Contact Details specified in this document, throughout our other Privacy policies, or through our site.
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. If you think any personal data we have about you is incorrect, you can request that we fix and correct these errors at any time. We will make these alterations within one calendar month from the date after which we can 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.
If you would like to “erase’ and effectively delete all of your data, you may notify us at any time and we will provide this service within one calendar month from the date on which you request it. Your right to deletion of your data does not cover aggregated and anonymized data.
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. We will change your preferences immediately after your objection to the processing of your data for marketing purposes, after which your personal data will no longer be used for marketing or promotional purposes, including contest entries. 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:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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
- 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
This Web Application is not intended for children and we do not knowingly collect data relating to children.
We require parental consent prior to the use of our application for anyone under the age of 16. If you are under the age of 16 and wish to use our Web App, we will need parental consent before you can do so.
If you are aware of the use of this Web App by an individual under the age of 16, please inform us and we will take appropriate action immediately.
We do not take responsibility for the use of our Web App by children under the age of 16 where the engagement with our Web App was accomplished through the intentional or accidental supply of false information to us.
Lawful basis: All personal data that we collect, process, transfer or retain relies upon a lawful basis of consent. We will never process your personal data without your consent. Consent may be explicit or implicit depending on the circumstances. Please take care to read all Glossary terms and refer to the table Purposes for which we will use your personal data for more details on your consent to our processing.
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.
12. DESCRIPTION OF THE CATEGORIES OF PERSONAL DATA
The following is a description of how an individual piece of data falls into the categories we use to process them.
Note that we do not process all of the data types listed below.
Where we wish to process a new type of data, we will inform you and you will be given an opportunity to withdraw your consent through a prompt on our Web Application, by logging into our site, or in rare cases by email. You will always be prompted before continuing to use our goods or services.
Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data: billing address, delivery address, home address, email address and telephone numbers.
Financial Data: bank account and payment card details.
Transaction Data: includes details about payments to and from you and details of in-App purchases.
Device Data: includes the type of mobile device you use, unique device identifiers (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), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, full IP address, and Browser type.
Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content.
Profile Data: includes your username (which is also your email) and password, in-App purchase history, your interests, preferences, feedback and survey responses. Note that we do not have access to your password and cannot provide it to you in the event of loss.
Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.