SPOTLA PRIVACY AND COOKIES POLICY
This is the privacy and cookies policy for Spotla (App) and www.flynetapp.io (Site). The App and Site are operated by AscendLondon Ltd, and its affiliated companies (we, us and our). We are an incorporated company, registered London, United Kingdom. Our registered company number is 8832994, and our office is at Hereford House, Unit 7, SW18 5SH, London, United Kingdom. For the purposes of the Data Protection Act 1998, we are the data controller.
We are committed to protecting your privacy. We appreciate that you do not want your personal information distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.
Information we may collect from you
We may collect and process the following information about you (whether it is submitted by you or collected by us about you and your device (Device)):
- information (such as your name, address (billing) email address and phone number, the Device phone number, financial and credit card information) that you provide by completing forms on the App and/or Site, including if you register as a user of the App, download or register an App, subscribe to any service, upload or submit any material via the App, make an in-App purchase, request any information, or enter into any competition or promotion we may sponsor;
- in connection with an account sign-in facility, your log-in and password details;details of any transactions made by you through the App;
- communications you send to us, for example to report a problem or to submit ueries, concerns or comments regarding the App, the Site or related content;
- information from surveys that we may, from time to time, run on the App for research purposes, if you choose to respond to, or participate in, them; and/or
- details of your use of our App and/or Site or your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with some or all of our services.
When you visit the Site or use the App, we may, by means of cookies and/or other similar technologies, automatically collect additional information about you – such as the type of internet browser or mobile device you use, any website from which you have come to the App, and/or Site, your IP address (the unique address which identifies your computer or mobile device on the internet), mobile network information, mobile operating system, time zone setting and/or the operating system of your computer or mobile device.
We collect information through the App and/or Site as to your real time location to provide location services where requested or agreed to by you in order to deliver content or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the App and/or Site.
Delivery of location services may involve reference to (a) the look-up of your country of location by reference to your IP address against public sources; (b) your IMEI or IMSI details; (c) your MMC, MCC or operator details; and/or (b) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier.
You may opt out at any time from allowing further access by us to your location data by un-installing the App. You may use the standard un-install processes as may be available for your Device.
You can also stop all information collection on the App by un-installing the App. You may use the standard un-install processes as may be available for your Device.
Cookies and other technologies
When you interact with the Site, we try to make that experience simple and meaningful. When you visit the Site, a web server sends a cookie or other similar technology to your computer or Device (as the case may be). Cookies are small pieces of information which are issued to your computer or Device (as the case may be) when you visit a website and which store and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer.
The cookies and/or other similar technologies we use collect information, such as the type of internet browser or Device you use, any website from which you have come to the Site, your IP address and/or the operating system of your computer or Device.
- remember that you have visited us before. This means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;
- customise elements of the promotional layout and/or content of the pages of the Site; and
- collect anonymous statistical information about how you use the Site (including how long you spend on the Site) and where you have come to the Site from, so that we can improve the Site and learn which parts of the Site are most popular with users.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
Uses made of your information
We use your personal information which we collect:
- to enable us to process your transactions and to provide you with the services and information offered through the App and the Site and which you request;
- to administer your account with us;
- to verify and carry out financial transactions in relation to payments you make online;
- to audit the downloading of data from the App;
- to improve the layout and/or content of the pages of the App, the Site and customise them for users;
- to improve the services we provide to you;
- to identify visitors to the App and to the Site;
- to carry out research on our users’ demographics;
- to send you information we think you may find useful or which you have requested from us, including information about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes;
- for compliance and auditing purposes;
- to allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services.
You can tell us not to contact you with information regarding our products and services or those of third parties or to share your details with third parties so that they can send you information regarding their products and services, by contacting us on the details below. For completeness, if you choose to use a third party’s services subsequent to use of our service, you may need to unsubscribe from their communications by way of their indicated process.
We may disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the App, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, auditing purposes, providing IT and other support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
We may disclose aggregate statistics about visitors to the App and customers in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber crime or to protect the App or the rights, property or personal safety of any person.
We may also disclose your personal information for the purpose of enforcing our terms and conditions, end user licence agreement or other agreements or to investigate potential breaches.
The App and the Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
We place great importance on the security of all personal information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the App or Site whilst it is in transit over the internet and any such submission is at your own risk.
It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.
Storage of your information
Your personal information which we collect is sent to and stored on secure servers currently located in the United Kingdom, Hong Kong and/or United States (depending on your location). Such storage is necessary in order to process the information. Personal information submitted may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your personal information we will take all reasonable steps to ensure that your privacy rights continue to be protected. By using the App or Site, you agree to this storing, processing and/or transfer.
You have a legal right under the Data Protection Act 1998 to a copy of all the personal information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct any errors in that information. As mentioned above, you have a right to prevent the use of your personal information for direct marketing purposes.