Pocket Angel Privacy Policy

Pocket Angel CIC (collectively referred to as “Pocket Angel”, “we”, “us” or “our” in this Privacy Policy) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our Digital Platform (as defined below) and tell you about your privacy rights and how the law protects you.

General information

 

Who we are.  Pocket Angel is a community interest company registered in England and Wales with our registered office at Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA, United Kingdom. Our company number is 12388196. We refer to ourselves as “Pocket Angel”, “we”, “us” or “our” in this Privacy Policy.

What this document is about.  You are reading a legal document, which sets our policy for collecting and processing your Personal Data when you use our Digital Platform.

What we do.  We operate a Digital Platform which allows the public to provide immediate support to homeless people using a cashless model. We provide a platform for our Users to make voucher-based donations, which is described in more detail in our Terms and Conditions.

How to contact us. You can contact us by writing to us at admin@pocketangelhome.co.uk.

Why you should read this Privacy Policy and what it covers. 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 and it is important that you read that information.

Other terms that may apply to you. This Privacy Policy refers to the following additional terms, which also apply to your use of our Digital Platform:

• our Terms and Conditions https://www.pocketangelhome.co.uk/app-tcs/; and
• our Cookie Policy https://www.pocketangelhome.co.uk/cookies-and-privacy/.

By using our Pocket Angel website or installing our Digital Platform, you accept the terms of this Privacy Policy.  By using our Pocket Angel website (accessible at https://www.pocketangelhome.co.uk) or installing our Digital Platform, you confirm that you accept this Privacy Policy. If you do not agree to these terms, you must not use our Digital Platform. We recommend that you print a copy of these terms for future reference. You consent to our processing of your personal data) as described in this Privacy Policy.

How you can withdraw consent. Once you provide consent by using our Digital Platform, you may change your mind and withdraw consent at any time by contacting us at the email address set out above but that will not affect the lawfulness of any processing carried out before you withdraw your consent. You must not use our Digital Platform if you withdraw consent.

Data Privacy Manager. We have appointed a data privacy manager. If you have any questions about this Privacy Policy, please contact them at admin@pocketangelhome.co.uk and include “Data Protection” in the subject line.

1.     Definitions and Interpretation

Cookies means small data sets stored on the device of the User;

Data Controller (or Owner) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of our Digital Platform. The Data Controller, unless otherwise specified, is Pocket Angel CIC;

Data Processor means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller, as described in this Privacy Policy;

Data Subject means the natural person to whom the Personal Data refers;

Digital Platform means:

• the Pocket Angel iOS and Android mobile application, which we refer to as “Pocket Angel Assist”;

• the Pocket Angel website (accessible at http://www.pocketangelhome.co.uk/);

• all digital platforms, subsisting now or in the future, that serve or enable other products or services; and

• any other forms, documents or sign-up sheets used by Pocket Angel, by which the Personal Data of the User is collected and processed;

European Union (or EU) means the European Union include all current member states of the European Union and the European Economic Area;

Personal Data means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person;

Service means the service provided by us on our Digital Platform described in the relevant terms (if available) and on this website or mobile application;

Usage Data means information collected automatically through our Digital Platform (or third-party services employed in our Digital Platform), which can include: the internet protocol (IP) addresses or domain names of the computers utilised by the Users who use our Digital Platform, the Uniform Resource Identifier (URI) addresses, the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g. the time spent on each page within the application), the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment; and

User means the individual using our Digital Platform who, unless otherwise specified, coincides with the Data Subject.

In this Privacy Policy, unless the context requires otherwise:

• references to a person include any individual, firm, body corporate (wherever incorporated), government, state or agency of a state or any joint venture, association, partnership, works council or employee representative body (in any case, whether or not it has separate legal personality);
• references to a paragraph or clause are to those of this Privacy Policy;
• headings do not affect its interpretation;
• the singular shall include the plural and vice versa, and references to one gender include all genders; and
• any phrase introduced by the terms “including”, “include”, “in particular” or any similar expression shall be construed as merely illustrative and shall not limit the sense of the words preceding those terms.

 

2. Who we are

 

Full name of Data Controller:                       Pocket Angel CIC

 

Email address of Data Controller:               admin@pocketangelhome.co.uk

 

Postal address of Data Controller:               Pocket Angel

Lytchett House

13 Freeland Park

Wareham Road

Poole

Dorset

BH16 6FA

 

3. What Personal Data we collect about you

 

We may collect, use, store and transfer different kinds of Personal Data about you, which we have grouped together as follows:

• Identity Data, which include your first name, last name, username or similar identifier;
• Contact Data, which include your billing address, delivery address, email address and telephone numbers;
• Location Data, which include your location, GPS coordinates, and recent whereabouts;
• Transaction Data, which include details about donations from you and other details of products and services you have donated through us, or with respect to service Users, that are provided to you;
• Technical Data, which include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Digital Platform;
• Profile Data, which include your username and password and donations made by you;
• Usage Data, which include the Usage Data and information about how you use our Digital Platform, products and services; and
• Marketing and Communications Data, which include your preferences in receiving marketing from us and our third parties and your communication preferences.

 

The above listed categories of Personal Data are collectively described below as the Data.

 

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, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using our Digital Platform.

 

4. How and why we use your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

 

• where we need to perform the contract we are about to enter into or have entered into 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 obligation;
• where we suspect malicious or fraudulent activity; and
• where we need to handle payments or analyse our Users’ experience.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:
  • to register you as a new donor or service provider and create an account on our Digital Platform;
  • to process and deliver your donation or, in the case of a service provider, provide payment of donation to enable you to deliver your service, including managing payments, fees and charges;
  • to support your use of our Digital Platform, including showing nearby locations that are providing Pocket Angel services;
  • to manage our relationship with you, which will include:
    • providing you with updates to help you donate or deliver your service;
    • notifying you about changes to our Terms and Conditions, Cookies Policy or this Privacy Policy; and
    • asking you to leave reviews or take surveys;
  • to administer and protect our community interest company and our Digital Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • to use data analytics to improve our Digital Platform, products/services, marketing, donor/service user relationships and experiences, including but not limited to the processing of data using Webtrends Analytics; or
  • to give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Digital Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using Cookies and other similar technologies. Please see our Cookies Policy for further details.
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties as set out below:
  • Technical Data from Webtrends Analytics. Webtrends Analytics is an analytics service provided by Webtrends Inc. Its place of processing is the United States. You can view its privacy policy here. Webtrends Analytics is a Privacy Shield participant; and
  • Contact Data, Financial Data and Transaction Data from PayPal provided when you make a donation or, in the case of a service provider, when we make a payment to your account.

Unless specified otherwise, all Data requested by our Digital Platform is mandatory and failure to provide this Data may make it impossible for our Digital Platform to provide its services. In cases where our Digital Platform specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner at the email address provided at the beginning of this document.

 

We use Cookies to provide our Service to our Users. You can set your browser to refuse all or some browser Cookies, or to alert you when websites set or access Cookies. If you disable or refuse Cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

 

Users are responsible for any third-party Personal Data obtained, published or shared through our Digital Platform and confirm that they have the third party’s consent to provide the Data to the Owner.

 

5. How we process and store your Personal Data

 

Method of processing

We use computers and other digital tools to collect your data. We will only process and store your Personal Data for the purposes specified above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Additionally, we have put in place procedures to deal with your data for the purposes indicated.

 

We may make your Personal Data available to certain people involved with the operation (for example those in administrative, sales, marketing, legal, or system administration) of our Digital Platform or third parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed. You may request the list of people we share your data with at any time.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Lawful basis for processing

We may process your Personal Data if one or more of the following applies:

• you have given your consent for one or more specific purposes;
• it is necessary for the performance of a contract with you;
• it is necessary to comply with a legal obligation; or
• it is necessary for the following legitimate interests:
  • facilitate donations from our Users to our Service Providers;
  • maintain and update our records;
  • assess how Donor and Service Providers use our products/services;
  • develop the products/services that Pocket Angel offers;
  • provide administration and IT services;
  • protect our network security and prevent fraud; and
  • maintain and update our Digital Platform.

 

We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground applies.

 

Place

We may process your Personal Data in any place where the parties involved in the hosting and processing are located. Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

Retention time

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. As such, where Data is collected for purposes related to the performance of a contract, it shall be retained until the contract has been fully performed. Where Data is collected for the purposes related to our legitimate interests, it shall be retained as long as needed to fulfil such purposes.

 

We may retain your personal data for a longer period where you have given consent to such processing, in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

The Data shall be deleted once this retention period expires. Once the Data has been deleted, you will not be able to enforce some of your rights as set out below.

 

6. Third parties

 

Third parties include:

• service providers acting as processors based in the US and UK who provide IT and system administration services;
• professional advisers acting as processors or joint controllers including lawyers, auditors and insurers based in the United Kingdom who provide legal, insurance and accounting services; and
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

7. Your rights

 

As a User, 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. 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.

 

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.
• 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.

 

Details about the right to object to processing

When processing your Personal Data, we are relying on a legitimate interest (or that of a third party), a public interest, or an official authority vested us. You have the right to object to the processing where 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. You may do so by providing a ground related to their particular situation to justify the objection. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Where we are processing your Personal Data for direct marketing purposes, you can object to that processing at any time by contacting us at the email address set out above without providing any justification.

 

How to exercise these rights

If you would like to exercise any of the abovementioned rights, please contact us using the contact details provided at the beginning of this document.

 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

8. Additional information about Data collection and processing

 

Legal action

Your Personal Data may be used by us as part of a dispute resolution procedure for any legal action arising from improper use of our Digital Platform. You understand and agree Pocket Angel may be required to disclosure your Personal Data upon the request of public authorities.

 

System logs and maintenance

Pocket Angel’s Digital Platform and any third-party services may collect information deriving from your interaction with our Digital Platform (for example system logs and analytics) and some of this information may contain Personal Data (such as your IP address).

 

Any information not contained in this Privacy Policy

You can request further details about the collection or processing of Personal Data from Pocket Angel at any time. Please use the contact information provided at the beginning of this Privacy Policy.

 

How “Do Not Track” requests are handled

The Pocket Angel Digital Platform does not support “Do Not Track”. To check if any of our third party providers support “Do Not Track” requests, please read their respective privacy policies.

 

Changes to this Privacy Policy

 

Pocket Angel reserves the right to update this Privacy Policy from time to time. To ensure the Personal Data we hold about you is accurate and current, please keep us informed of any changes in your Personal Data.