POLICY ON PRIVACY, DATA, COOKIES AND MARKETING COMMUNICATIONS
This Policy sets out how Six to Start Limited (“we” / “our”) may obtain and use certain personal and non-personal information which we may acquire when you download and interact with the “Step Buy Step” App (the “App”). You should carefully review this policy prior to downloading and using the App.
Date of last update: 3 November 2014.
1. About us
1.1. Six To Start Limited is a company registered in England, with our registered office address at Unit 11 Spectrum House, 32 Gordon House Road, London, NW5 1LP. Our company number is 6289098. For the purposes of the Data Protection Act 1998, we are the data controller in respect of any personal data which you may submit to us.
2.1 We may ask you for and / or you may submit certain personal and non-personal information and / or data to it through the App (such as your name, email address, password, contact details, height, weight, calories expended, game play logs, Twitter ID and Facebook ID) and information concerning your use of the App when you use the App or any of its related services.
2.2 We may also record which parts of the App and its related features and services you are interested in and your usage patterns.
2.3 This information will be kept secure by us in accordance with the Data Protection Act 1998 and may be used to:
2.3.1 process and make available the App;
2.3.2 enable your use of the App and associated services;
2.3.3 open and run your user account and provide you with an up to date, efficient and reliable service;
2.3.4 monitor the use of the App;
2.3.5 monitor your contributions (if any);
2.3.6 keep you updated on the App news and developments and related services;
2.3.7 to generate anonymous and aggregate data reports to highlight the use of the App; and
2.3.8 to comply with any Apple policy or law enforcement request.
2.4 By submitting your data and using the App you agree to this use.
2.5 WE WILL ONLY USE INFORMATION COLLECTED ABOUT YOU IN ACCORDANCE WITH THE DATA PROTECTION ACT 1998.
2.6 We will never collect sensitive information about you without your explicit consent.
2.7 If you believe we have information about you that you do not want us to have or that is incorrect please contact us as described below and we shall correct or remove the data as you request as soon as is reasonably practicable and/or provide details to you of how you can update the data.
2.9 We may use servers outside the EEA to store any data which we acquire from your use of the App, and where we do so, we shall ensure that our data processors agree to handle the data in accordance with the Data Protection Act 1998.
2.10 We will use reasonable and industry standard measures to safeguard the personal data we hold. However no system can be 100% secure, and therefore despite our best efforts, there could be unauthorised access to this data and therefore by using the App you accept this risk.
2.11 In the event that Six to Start Limited is subject to a purchase or all or some of its assets are acquired by a third party, then the personal data shall be deemed an asset which may be transferred to the third party.
2.12 Please note that if you are below the age of 16 you should not provide any personal data to us. If you older than 16 years of age, but below 18 years of age you should obtain the consent of your parent or guardian before you submit personal data to us.
3.1 As part of the App, you may create your own profile showing your progress through the game, and also your runs and other data (including personal data) which you have submitted to us. The default setting of the App will not share this information with other users of the App or the general public, but you may opt to share this information with your friends and the general public.
3.2 You may also opt to share your information and use of the App on social networks such as Facebook and Twitter. You should check your privacy settings of those networks to ensure you are happy with the way your information is shared.
5. Marketing Communications
5.1 We shall give you a choice of whether or not you want us or other reputable companies chosen by us to contact you about future offers, events and new services or related activities that we believe you may find useful.
5.2 We will not sell or trade personal information to other companies but we would like to keep you informed of the developments on the App and certain games and we would like to share data with other reputable companies who may have interesting offers and information for you (inside or outside the EU).
5.3 We will not send you any marketing emails or pass your information on to third parties unless you give your consent or you have given it already.
6. In App Adverts
6.1 Our App may have advertising displayed within it, as part of the Apple iAd Network, and we are not responsible for the selection and serving of adverts.