PRIVACY POLICY

 

The Blushy Services are owned and operated by Machine Town Limited 

Machine Town Ltd ("we" or “us”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents linked to in this policy or in our terms) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This privacy policy (“Policy”) applies to personal data that we collect from you.

It is important that you read this Policy so that you are fully aware of how and why we are using your data.

 

The Policy consists of the following sections:

  1. IMPORTANT INFORMATION AND WHO WE ARE

  2. CHANGES TO THIS POLICY AND YOUR DUTY TO LET US KNOW OF CHANGES

  3. PERSONAL DATA WE MAY COLLECT AND WHERE WE GET IT FROM

  4. USES MADE OF YOUR PERSONAL INFORMATION

  5. HOW WE SHARE INFORMATION

  6. SECURITY

  7. MAINTENANCE AND RETENTION OF PERSONAL DATA

  8. OTHER WEBSITES

1. IMPORTANT INFORMATION AND WHO WE ARE

The data controller who is responsible for your personal data is Machine Town Ltd (a company registered in England and Wales with company number 11187605) with its registered office at Kemp House, 160 City Road, London EC1V 2NX.

If you have any questions or concerns relating to your personal data or this Policy, please contact us: contact@blushy.app

Whilst you have the right to make a complaint at any time to the Informational Commissioner’s Office (www.ico.org.uk), we would like to have a chance to deal with any concerns before you approach the ICO.

2. CHANGES TO THIS POLICY AND YOUR DUTY TO LET US KNOW OF CHANGES

This Policy was last updated on 25th February 2019. We may need to make updates or changes to this Policy from time to time. Please check this page regularly so that you are aware of any changes.

Please let us know if your personal information changes during your relationship with us so that we can update our records.

3. PERSONAL DATA WE MAY COLLECT AND WHERE WE GET IT FROM

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and process the following types of personal data about you: 

INFORMATION THAT YOU PROVIDE TO US

We will process personal information that you give to us when you register to use our application and/or when you use our service, as follows:

  • your name and surname

  • your personal contact information (email.);

  • your username and password;

  • your user profile data (e.g., workout schedule);

  • your user preferences (e.g., preferred language settings);

  • your service inquiries and your orders;

  • your transaction history, including open and completed transactions;

  • search terms you input;

  • information regarding your orders and payments;

  • information collected by cookies or similar technologies (as explained below);

  • your survey answers, critiques, evaluations, or other responses;

  • information about workouts you download using the Blushy App;

  • any consents you have given us;

 

INFORMATION WE OTHERWISE COLLECT FROM YOU

As you interact with our website, we may use various technologies to collect and store information about your equipment, browsing actions and patterns and how you use and interact with our website. This information may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and version and the content you view. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

INFORMATION WE OBTAIN FROM OTHER SOURCES

We may also obtain information relating to how you use our website and services from analytics providers (such as Google Analytics).

 

AGGREGATED DATA

We may also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data as it does not directly or indirectly reveal your identity. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

 

4. USES MADE OF YOUR PERSONAL INFORMATION

HOW WE MAY USE YOUR PERSONAL INFORMATION

 

We may do the following with your personal information:

 

  1. Use it to provide our services to you – i.e. to personalise the content we provide for your needs

  2. To contact you, if necessary, in connection with our services

  3. To engage in marketing and business development activity in relation to our services. This may include sending you newsletters, marketing communications and other information that may be of interest to you

  4. To comply with any legal and regulatory obligations that we have to discharge

  5. To record and monitor your use of our website and/or other services for our business purposes which may include analysis of usage and generation of reporting

  6. For our legitimate business interests such as managing the operation of our website and our business, troubleshooting, testing and undertaking business research and analysis

  7. We may use your personal information to prevent and respond to actual or potential fraud or illegal activities


 

GROUNDS FOR USING YOUR PERSONAL INFORMATION

 

We will only use your personal data when the law allows us to, namely:

 

  1. Performance of a contract: we may need to collect and use your information to enter into a contract with you or to perform our obligations under a contract with you.

  1. Legitimate interest – we may use your personal information for our legitimate business interests, some examples of which are listed above

  2. Compliance with law or regulation – we may use your information to comply with a legal or regulatory obligation.

  3. Consent - generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you. You can withdraw consent by contacting us (see above).

 

Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

 

5. HOW WE SHARE INFORMATION

We may have to share your personal data with the third parties set out below for the purposes set out above:

 

  • Third party agents/suppliers or contractors in connection with the processing of your personal information described in this Policy including, but not limited to, payment processors and IT and communications service providers.

 

  • To the extent required by law, regulation or court order or if we believe in good faith that such action is necessary to comply with legal requirements or process, prevent a crime or protect national security.

 

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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

Your information may be transferred to locations outside of Europe, as well as within it. Where we transfer your personal information outside of Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of ways, for instance:

  • The country to which we sent the personal information may be approved by the European Commission

  • The recipient may have signed a contract based on “model-contractual clauses” approved by the European Commission, obligating them to protect your personal information, or

  • Where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.

In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law. You can obtain more details of the protection given to your personal information when it is transferred outside Europe by contacting us.

 

6. SECURITY

Although the transmission of data over the internet may be subject to intrusion, we protect your personal data by ensuring we have implemented appropriate physical, electronic and procedural safeguards to avoid unauthorised access or disclosure, accidental loss, use, alteration or destruction of such Information.

Where we engage third-party contractors, as far as is necessary, we may share Information in order for such parties to perform services on our behalf. 

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.

 

7. MAINTENANCE AND RETENTION OF PERSONAL DATA

You have certain rights in relation to your personal data. Please contact us by email, should you wish to: 

  1. Request access to your personal data – enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.

  1. Request correction of your personal data – you may correct any inaccuracies or incomplete data although we may need to verify the accuracy of the new data you provide.

  1. Request erasure of your personal data - where there’s no good reason for us to continue to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law.

  1. Object to processing of your personal data – where we are relying on a legitimate interest and you object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also object where we are processing your data for marketing purposes.

  1. Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  1. Request transfer of your personal data – you may request that we transfer data to you or a third party. This 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.

  1. Withdraw consent to our use of your personal data – where we are relying on consent. This will not affect the lawfulness of processing that we carried out before you withdraw consent. If you withdraw consent, we may not be able to provide products or services to you.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of these rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex in which case we will let you know and keep you updated.

HOW LONG WE HOLD YOUR PERSONAL INFORMATION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

8. OTHER WEBSITES

This Policy applies to our services only. Our websites may contain links to third-party websites, plug-ins and applications over which we have no control. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the privacy policies or practices of such other websites and we encourage you to review the privacy policies, if any, on all such websites.

 

We reserve the right to update this Policy from time to time.

Dated: 25 February 2019

 

 

 

 

 

© 2019 Blushy. All rights reserved. Blushy is a Trading Name of Machine Town Ltd. 

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