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Footij Privacy Policy

Introduction

This policy (together with our terms of service as set out at https://footij.net/terms-of-service and any additional terms of use incorporated by reference into the Terms) applies to your use of the Footij mobile application, websites, software and services (Footij), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device.

We may also process personal information relating to individuals who appear in content posted to Footij and provide more information about how we use this information in this policy.

This policy sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Footij Ltd is the controller and is responsible for your personal data (referred to as "we", "us" or "our" in this policy).

Contact details

Our full details are:

  • Full name of legal entity: Footij Limited, a company registered in England with company number 12233394 with our registered office at Unit D South Cambridge Business Park, Babraham Road, Cambridge, Cambridgeshire, England, CB22 3JH.
  • info@footij.net
Please do let us know if you have any questions or concerns with the way in which we process your personal information. In addition you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if you are based in another EU member state.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on January 3rd 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start Footij. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of Footij.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Reporting Inappropriate Content

If you believe that any content on Footij breaches the terms of this policy or our other Terms or is otherwise inappropriate in any way please contact us at info@footij.net.

Third party links

Footij may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you including:

  • ● Identity Data: first name, last name, username or similar identifier, playing age group, gender.
  • Image Data: photographic or video images
  • Contact Data: email address
  • Device Data: includes [the type of mobile device you use,] [a unique device identifier [(for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device)],] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,].
  • Content Data: includes information uploaded to Footij, including login information, photos, videos or other digital content.
  • Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data: includes details of your use of any of Footij including, but not limited to, traffic data and the resources that you access (for example, opening the app and viewing videos).
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature. However, 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 privacy policy.

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.

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Image, Contact, Content, Profile and Marketing and Communications Data) you upload to Footij, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use Footij, upload video and other content to Footij, share data via social media functions, enter a competition, promotion or survey and when you report a problem with Footij. If you contact us, we will keep a record of that correspondence.
  • Information in user produced content. This is information included in video and other content that our users upload to Footij and will include Image and Content Data. We will not usually know who you are or have any practical means to contact you but it is possible that you may be identifiable from this content.
  • Information we collect about you and your device. Each time you use Footij we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
  • Information we receive from analytics providers. We will receive personal data about you from analytics providers such as Google.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of Footij and to remember your preferences. This helps us to provide you with a good experience when you use Footij and also allows us to improve our services.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where it is necessary to perform a contract we are about to enter or have entered 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 or regulatory obligation.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. You can withdraw your consent at any time by contacting us or closing your Footij account.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

We rely on different legal bases for processing different types of your personal data for different purposes. The table below sets out a summary of the main purposes for which we process different types of data and the lawful basis that we rely on for this processing. However, if you would like more information about any specific processing that we undertake please do contact us.

Purpose/activity Type of data Lawful basis for processing
To install Footij and register you as a new user of Footij Identity
Contact
Device
Your consent Performance of a contract with you
To allow you to upload and share content on Footij Image
Content
Your consent
Profile Performance of a contract with you

Necessary for our legitimate interests (to develop and provide the Footij services to our users and grow our business)
To manage our relationship with you including notifying you of changes to Footij Identity
Contact
Profile
Marketing and Communications
Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey Identity Image Content Contact Device Profile Marketing and Communications Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business including troubleshooting, data analysis and system testing Identity Contact Device Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve Footij Identity Image Contact Device Content Profile Usage Marketing and Communications Location Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
To include in our user generated content on Footij Image Content Necessary for our legitimate interests (to develop and provide the Footij services to our users and grow our business)

Disclosures of your personal data

When you upload Image or Content Data to Footij you have the option of sharing that information publicly or to a private group. Any Image and Content Data may include personal data and you should ensure that you select the appropriate privacy settings and only share personal data on Footij with those that you wish to share this with.

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

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Our advertising partners who we allow to use any of the content that you share on Footij in accordance with our Terms, but we will not share your contact details without your express agreement.
  • HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Law enforcement and other regulatory and public bodies if we suspect any unlawful content on Footij or consider any safeguarding risks to individuals.
  • 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 privacy policy.

Profiling

We may use any of the personal data that you have provided to us to help us target content, including advertising and promotional content to you, based on our understanding of your interest.

International transfers

Some of our external service providers who allow us to deliver Footij to you are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We ensure that such transfers are to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on encrypted cloud based servers and is only accessible by us and our service providers that have a need to access this to provide and improve the Footij service. You are responsible for keeping your passwords confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

You should ensure when sharing videos and other content on Footij that you do not submit any personal data that you do not want to be seen, collected or used by other users. You can use the tools within Footij to determine who you share content with.

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

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

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:

    1. if you want us to establish the data's accuracy;
    2. where our use of the data is unlawful but you do not want us to erase it;
    3. 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
    4. 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.
  • You also have the right to ask us not to continue to process your personal data for marketing purposes.

    You can exercise any of these rights at any time by contacting us at Unit D South Cambridge Business Park, Babraham Road, Cambridge, Cambridgeshire, England, CB22 3JH OR info@footij.net.

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