ROOT38 Privacy Policy

Effective Date: 25th May 2018

Your data is important. It's important to us, and we understand that it's important to you.

ROOT38 Limited is committed to safeguarding your information in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information.

ABOUT THIS POLICY

This privacy policy covers the collection and use of your personal information by us and parties that we authorise.

It applies to our services (the "Services") including our mobile applications and websites.

By accessing and using our services, you agree to the terms of this Privacy Policy. We may update this Privacy Policy from time to time and we'll alert you to any changes within both our mobile applications and on our websites.

In this policy, "We", "Us" and "Our" means ROOT38 Limited.

WHAT INFORMATION DO YOU COLLECT?

When you use our services, you provide us with two types of information: (i) personal information you submit via the service and (ii) usage information regarding your use of the service collected by us as you interact with the service.

When you enter our websites, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet). In addition, we store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on our websites.

When you use our mobile applications, we collect your device type, your device ID and your IP address. You may also provide us with your name and email address.

When you use our Event Countdown mobile application, you may submit the details of an event including the date it takes place. You may share this information with other users.

When you use our Exam Countdown mobile application, you may submit the details of your exams including the date and time they take place and your exam results. You may share this information with other users.

When you use our iKnow mobile application, you may submit the details of the subjects you study, notes and exam or revision sessions including the dates and times they take place. You may also submit details of your self-assessed competency in specific subject areas and topics. You may share this information with other users.

We store this information, so that we can provide you the service and offer personalised features. Some of our services may only be available if you provide us with the information requested. It is your responsibility to ensure that any information you provide us is accurate and kept up to date. We do not share your personal information with third-parties unless it is necessary to offer the Service or required by law (see below for specifics).

HOW WILL WE USE YOUR INFORMATION?

We may use your contact information to send you notifications regarding new services offered by ROOT38 that we think you may find valuable. ROOT38 may also send you service-related announcements from time to time through the general operation of the Service. Generally, you may opt out of such emails.

When using our mobile applications, if you choose to invite other users to view your event or exam information, the name you provide will be visible to these users. The name you provide will also be visible to users who's events you follow.

ROOT38 may use or share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

HOW WILL THIRD PARTIES USE YOUR INFORMATION?

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

CLOUD SERVICES AND ANALYTICS

We may use third-party Service Providers to store information, monitor and analyse the use of our service.

Firebase

Firebase is service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: http://www.google.com/intl/en/policies/privacy/

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

For more information on what type of information Firebase collects, please visit please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

ADVERTISING

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

AdMob by Google

AdMob by Google is provided by Google Inc.

You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of Google: http://www.google.com/policies/privacy/

You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative ("NAI") or who follow the DAA Self-Regulatory Principles for Online Behavioural Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here http://www.networkadvertising.org/choices/ and the DAA's opt out tool can be found here http://www.aboutads.info/choices/.

In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioural advertising (for example, Apple iOS' Advertising ID and Google Android's Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

HOW WILL YOU SHARE PERSONALLY-IDENTIFIABLE INFORMATION WITH THIRD PARTIES?

ROOT38 shares your personally-identifiable information only when it is reasonably necessary to offer the Service, legally required, or permitted by you. For example:

We may be required to access and disclose personally-identifiable information in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we may access and share account or other personally-identifiable information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the service or using the ROOT38 name, or to prevent imminent harm.

This may include accessing and sharing personally-identifiable information with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the ROOT38 business, or individual business units or assets owned by ROOT38 that are related to the Service, were to change, your personally-identifiable information may be transferred to the new owner. In any such transfer of information, your personally-identifiable information would remain subject to this section.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example:

- we may need to keep some personal information about you so we can deal with any complaints you might make about the Services we provide to you

- if you ask us to stop processing your personal information for direct marketing, we need to retain enough information about you to enable us to ensure we stop including you in those direct marketing activities

- we may need to keep personal information so we can defend possible future legal claims

- we may have a legal or regulatory duty to retain particular personal information for a certain minimum period (for example under HMRC tax rules)

WHAT ARE YOUR RIGHTS?

Any personal information you supply will be treated in accordance with applicable data protection laws including the General Data Protection Regulation (the "GDPR") and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:

- the right to request a copy of the personal information we hold about you. To do this, please contact us at ben.sheehan@root38.com making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit a proof of your identity.

- the right to object to your personal information being used for direct marketing. Where required we will ensure we obtain your consent before undertaking marketing and you will have the ability to opt out.

- the right to object to your personal information being processed where the legal basis for the processing is our own legitimate interests as a business (see ‘How will we use your information?' section above). We will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our Services.

- the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information.

- the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time.

- the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal information, such as keeping your payment information for several years to comply with HMRC rules.

- the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible.

HOW SECURE IS MY INFORMATION?

The security of your data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 entitles residents of the State of California to request from a business, with whom that resident has an established business relationship, certain information regarding the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. If you would like to request a copy of this information disclosure from ROOT38, please contact us at ben.sheehan@root38.com

WHAT THIS PRIVACY POLICY DOES NOT COVER

This privacy notice doesn't cover companies, services or applications that we don't own or control, or people that we don't employ or manage. This includes (without limitation) third party websites or applications/widgets (e.g. from social media platforms such as Facebook or Twitter) that we link to or offer via our Services. Nor does it cover advertisers so if you click on an advert and it takes you to an advertiser site, please check their privacy notice.

Also, it doesn't cover certain pages and services provided via our services that are hosted, managed and operated by other parties. These third parties, applications and services are wholly independent of us and are solely responsible for all aspects of their relationship with you and any use you may make of them. They may have their own privacy notices and/or terms and conditions of use, which we recommend you read before using.

DATA CONTROLLER AND CONTACTING US

ROOT38 Limited is a company registered in England and Wales (registered number 10349589) with registered office at 7 Northwick Terrace, Wolverhampton, WV14 0AF, United Kingdom.

If you wish to contact us about our privacy notice, please email us at ben.sheehan@root38.com