1. Introduction to this Policy
1.1. This privacy policy (“Policy”) relates to the social planning website ‘Socirc’ available at socirc.co and any related website, subdomain, mobile application or other software application (together the “Site”).
1.2. You should read this Policy carefully as it contains important information about how we will use your Information (as defined below in clause 4.1). You will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit Information to or through the Site. If you do not consent to such processing you should not submit any Information through the Site. For further information about consent see clause 7 below.
1.3. We may update this Policy from time to time in accordance with clause 18 below. This Policy was last updated on 01st November 2022.
2. About us
2.1. The terms “Socirc” or “us” or “we” refer to Socirc, the owner of the Site and the Platform. We are a company registered in England and Wales whose registered office is situated at International House, 64 Nile Street, London, N1 7SR 6XP (“Socirc/we/us/our”)The term “you” refers to the individual submitting Information to the Site.
2.2. Our Data Protection Officer can be contacted on: hello@socirc.co
3. Data Protection
3.1. References in this Policy to:
3.1.1. “Data Protection Law” means: the Data Protection Act 2018 and, the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Regulation of Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic Communications Data Protection Directive (2002/58/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and
3.1.2. “Personal Data”, “Controller” and “Processor” and “processing” shall have the meanings given to them in the Data Protection Law.
3.2. For the purposes of applicable Data Protection Law, we socirc are a Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with Data Protection Law. “Personal Data” has a legal definition but, in brief, it refers to information from which a living person can be identified. Such information must be protected in accordance with Data Protection Law.
4. Information we may collect about you
4.1. When you use the Site and/or when you otherwise deal with us we may collect the following information about you (“Information”):
4.1.1. personal information including first and last name, date of birth, job title; photograph and/or likeness;
4.1.2. contact information including residential address, geographic position, primary email address and/or primary phone number;
4.1.3. if you sign up to the Site through a third-party social networking services such as Facebook (each an “SNS”), we may extract information from your applicable SNS account (for example your name, email address, photograph and/or likeness, event and activity information and other personal information that your privacy settings on the SNS Account permit us to access);
4.1.4. information about your connections and contacts when you invite others to participate in your Plans (as defined in our Site terms and conditions available here).
4.1.5. technical information including IP address, operating system, browser type and related information regarding the device you used to visit the Site, the length of your visit and your interactions with the Site;
4.1.6. information obtained through our correspondence and monitoring in accordance with clause 12 below; and 4.1.7.
other information relevant to services, customer surveys and/or offers.
4.2. We may monitor your use of the Site through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the Site. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. See clause 17 below for further information on our use of cookies.
4.3. Occasionally we may receive information about you from other sources, for example from other users of the Site who provide your contact details to us when creating or managing their Plans through the Site, or from SNS operators. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
5. How long we keep your Information
5.1.1. Subject to clause 5.2, we will keep your Information only for as long as we need to hold it for the purposes set out in clause 8 below.
5.1.2. If required, we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
6. Legal basis for processing your information
6.1. Under Data Protection Law, we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is:
6.1.1. Where we have requested it and made it known to you, your consent (for which see clause 7 below), or
6.1.2. because the processing is necessary for the performance of a contract you have entered into (i.e. your contract with us as set out in this Policy and our T&Cs) or for taking any preliminary steps that are required before you can enter into such a contract with us, provided we only do this at your request; or
6.1.3. subject to your rights set out in clause 15 below, the legitimate business interest of providing services to our users through the Site, which requires the processing of your Information to enable us to provide these services.
7. Your consent to processing
7.1. As noted above, you will be required to give consent to certain processing activities before we can process your Information. Where applicable, we will seek this consent from you when you first submit Information to or through the Site.
7.2. If you have previously given consent you may freely withdraw such consent at any time. You can do this by emailing: hello@socirc.co.
7.3 If you withdraw your consent, and if we do not have another legal basis for processing your information (see clause 6 above), then we will stop processing your Information. If we do have another legal basis for processing your information then we may continue to do so subject to your legal rights (for which see clause 15 below).
7.4. Please note that if we need to process your Information in order to operate the Site and/or provide our services, and you object or do not consent to us processing your Information, the Site and/or those services may not be available to you.
8. How we use your Information
8.1. We may process Information held about you for the following purposes:
8.1.1. to operate, administer, maintain, provide, analyse and improve the Site and the services available through the Site;
8.1.2. to investigate and address any comments, queries or complaints made by you regarding the Site, and any similar or related comments, queries or complaints from other users;
8.1.3. to ensure that content on the Site is presented in the most effective manner for you and for your device;
8.1.4. to conduct research, statistical analysis and behavioural analysis (including anonymizing data for these purposes);
8.1.5. to provide insights based on aggregated, anonymous data collected through the research and analysis referred to at 8.4 above;
8.1.6. to allow you to participate in interactive features of the Site, including inputting information and providing feedback;
8.1.7. to contact you for marketing purposes, where applicable (see 'Marketing and opting out' in clause 9 below);
8.1.8. to disclose your information to selected third parties as permitted by this policy (see clause 10 below);
8.1.9. to notify you about changes to the Site; and
8.1.10. o comply with our legal obligations, including obligations relating to the protection of Personal Data.
9. Marketing and opting out
9.1. If you have given permission, we may contact you through electronic messaging services including but not limited to email, text messages and similar services (“Messaging Services”) about our products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can withhold consent and/or opt out at any time (see below).
9.2. If you have given permission, we may contact you through Messaging Services to provide information about products, services, promotions, special offers and other information we think may be of interest to you from carefully selected third parties. We will inform you (before collecting your data) if we intend to use your data for such purposes. If you would rather not receive such third party marketing information from us, or you no longer wish to receive it, you can withhold consent and/or opt out at any time (see below).
9.3. If you have given permission, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) through Messaging Services about products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to disclose your data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can withhold consent and/or opt out at any time (see below).
9.4. You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to support@socirc.coor contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in emails or other communications you receive from us or them.
9.5. If you enter one of our competitions, our use of your data will be governed by this Privacy Policy, our competition terms and any Specific Competition Terms which apply.
10. Disclosure of your information
10.1. We may disclose your Information (including Personal Data):
10.1.1. to other companies within our group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);
10.1.2. to our business partners, service providers or third-party contractors to enable them to undertake services for us and/or on our behalf (and we will ensure they have appropriate measures in place to protect your Information);
10.1.3. to any prospective buyer or seller (and their representatives) in the event that we sell or buy any business or assets;
10.1.4. if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, including (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity; and
10.1.5. to other third parties if you have specifically consented to us doing so.
10.2. We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Site. In such circumstances we do not disclose any information which can identify you personally.
10.3. If our whole business is sold or integrated with another business your Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
11. Keeping your Information secure
11.1. We will use technical and organisational measures in accordance with good industry practice to safeguard your Information, including the use of data encryption.
11.2. While we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
12. Monitoring
12.1. We may monitor and record communications with you (such as telephone conversations and emails) for the purposes of provision of services, quality assurance, training, fraud prevention and compliance purposes. Any information that we receive through such monitoring and communication will be added to the information we already hold about you and may also be used for the purposes listed in clause 8 above.
13. Overseas transfers
13.1. From time to time we may need to transfer your Information to countries outside the European Economic Area, which comprises the EU member states plus Norway, Iceland and Liechtenstein (“EEA”). Non-EEA countries that we may need to transfer your Information to include the United States of America.
13.2. Such countries may not have similar protections in place regarding protection and use of your data as those set out in this Policy. Therefore, if we do transfer your Information to countries outside the EEA we will take reasonable steps in accordance with Data Protection Law to ensure adequate protections are in place to ensure the security of your Information.
13.3. By submitting your Information to us in accordance with this Policy you consent to these transfers for the purposes specified in this Policy.
14. Information about Invitees and other individuals
14.1. As part of our services we allow registered users to create Plans and send invitations to individuals (“Invitees”) to invite them to participate in these Plans. Where you wish to send an invitation to a proposed Invitee who is also a registered user on the Site we will process Personal Data that relates to that Invitee in accordance with this Policy.
14.2. Where you wish to send an invitation to a proposed Invitee who is not a registered user on the Site then, in order for us to contact them, we will only collect their mobile phone number and name (as it appears in your phone contacts directory) from you. At this stage we will not collect or request from you any other information from which that Invitee can be personally identifiable. Such mobile phone number and name alone do not constitute Personal Data since, without further information, we will not be able to personally identify the proposed Invitee(s). When we send the invitation to the proposed Invitee’s mobile phone number we will provide a link to the Site (including this Policy) and, if they access the Site, we will seek consent from them to process their Personal Data in accordance with this Policy.
14.3. Where we send invitations to proposed Invitees who are not registered users on the Site under clause 14.2 we give them the option to unsubscribe from receiving future invitations. If they do unsubscribe from receiving future invitations then we will not send any further invitations to them unless they expressly consent to us doing so. If you attempt to send an invitation to a proposed Invitee who has previously unsubscribed from receiving invitations then we will not contact that Invitee and, where applicable and where we are able to do so, we will inform you that we have not contacted that Invitee.
14.4. Subject to the above, if you otherwise give us Personal Data that relates to a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Personal Data; receive on his/her/their behalf any data protection notices; and give consent to the transfer of his/her/their Personal Data abroad (if applicable).
15. Your rightsIf you are an individual, this section sets out your legal rights in respect of any of your Personal Data that we are holding and/or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using our contact details in clause 21 below) giving us enough information to identify you and respond to your request.
15.1. You have the right to request information about Personal Data that we may hold and/or process about you, including: whether or not we are holding and/or processing your Personal Data; the extent of the Personal Data we are holding; and the purposes and extent of the processing.
15.2. You have the right to have any inaccurate information we hold about you be corrected and/or updated. If any of the Information that you have provided changes, or if you become aware of any inaccuracies in such Information, please let us know in writing giving us enough information deal with the change or correction.
15.3. From 18 December 2019 onwards you have the right in certain circumstances to request that we delete all Personal Data we hold about you (the ‘right of erasure’). Please note that this right of erasure is not available in all circumstances, for example where we need to retain the Personal Data for legal compliance purposes. If this is the case we will let you know.
15.4. From18 December 2019 onwards you have the right in certain circumstances to request that we restrict the processing of your Personal Data, for example where the Personal Data is inaccurate or where you have objected to the processing (see clause 15.6 below).
15.5. From18 December 2019 onwards you have the right in certain circumstances to request a copy of the Personal Data we hold about you and to have it provided in a structured format suitable for you to be able to transfer it to a different Controller (the ‘right to data portability’). Please note that the right to data portability is only available in some circumstances, for example where the processing is carried out by automated means. If you request the right to data portability and it is not available to you we will let you know.
15.6. You have the right in certain circumstances to object to the processing of your Personal Data. If so, we shall stop processing your Personal Data unless we can demonstrate sufficient and compelling legitimate grounds for continuing the processing which override your own interests. If, as a result of your circumstances, you do not have the right to object to such processing then we will let you know.
15.7. You have the right in certain circumstances not to be subject to a decision based solely on automated processing, for example where a computer algorithm (rather than a person) makes decisions which affect your contractual rights. Please note that this right is not available in all circumstances. If you request this right and it is not available to you we will let you know.
15.8. You have the right to object to direct marketing, for which see clause 9.4 above.
16. Complaints
If you have any concerns about how we collect or process your Information then you have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/
17. ‘Cookies’ and related software
17.1. Our software may issue ‘cookies’ (small text files) to your device when you access and use the Site and you will be asked to consent to this at the time (e.g. when you first visit our website). Cookies do not affect your privacy and security since a cookie cannot read data off your system or read cookie files created by other sites.
17.2. Our Site uses cookies and other tracking and monitoring software to: distinguish our users from one another; collect standard Internet log information; and to collect visitor behaviour information. The information is used to track user interactions with the Site and allows us to provide you with a good experience when you access the Site, helps us to improve our Site, and allows us to compile statistical reports on Site visitors and Site activity.
17.3. You can set your system not to accept cookies if you wish (for example by changing your browser settings so cookies are not accepted), however please note that some of our Site features may not function if you remove cookies from your system. For further general information about cookies please visit www.aboutcookies.org orwww.allaboutcookies.org
18. Changes to this Policy
18.1. We keep this Policy under regular review and may change it from time to time. If we change this Policy we will post the changes on this page, and place notices on other pages of the Site as applicable, so that you may be aware of the Information we collect and how we use it at all times. You are responsible for ensuring that you are aware of the most recent version this Policy as it will apply each time you access the Site.
18.2. This Policy was last updated on 01 November 2022.19. Links to other websitesOur Site may contain links to other websites. This Policy only applies to our Site. If you access links to other websites any Information you provide to them will be subject to the privacy policies of those other websites.20. Accessibility20. This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.21. Contact usWe welcome your feedback and questions on this Policy. If you wish to contact us or our Data Protection officer, please email us at feedback@socirc.co.
