Privacy Policy
Version: 1.0.
Date: 27 September 2023.
Applies to new customers from: 27 September 2023
Applies to customers who joined before 27 September 2023: n/a
Previous versions: n/a.
We are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you, what we do with it, and the legal basis for our processing. We also provide information about your rights and how to exercise them.
Who we are /details of data controller
The YumTuc app is operated by Globescoffing Ltd (Company Number 14543540). This policy applies to the app, and related websites. References to YumTuc, Globescoffing, ‘we’, ‘us’ or ‘our’ mean Globescoffing Ltd.
Globescoffing Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to hello@yumtuc.com or by post to Globescoffing Ltd, 124 City Road, London, EC1V 2NX. 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Other relevant documents
You should also review our Terms & Conditions which are published on our website and available within our app.
Lawful basis of processing
Under data protection laws, Globescoffing must have legal grounds to process your personal data. We consider the following grounds to be relevant:
Consent: where you have explicitly given us permission to collect, use and store your personal data for a specific reason or reasons. Generally we do not rely on consent as a legal basis for processing your personal data, but when we do you can withdraw your consent at any time.
Performance of a contract: in order to provide a service or product.
Legal obligation: where processing of the data is required by law, for example where we are required to provide information to a regulator or court.
Legitimate interest: where it is reasonable to achieve our and others legitimate interests, such as to understand how you interact with our app, to look out for and to fix faults, or to let you know about important changes to the services, their terms or this privacy policy.
More detail on the legal basis for the different ways we use your data is presented in the table below.
What information does Globescoffing collect?
We may collect, store and use the following types of information about you depending on how you interact with our services:
Identity data: specifically your name and – in some cases – a username and password you select to access the service.
Contact data: specifically your email address. This may be collected directly from you and/or provided to us on your behalf by a federated identity provider.
Location data: If granted permission to do so by you when using our app, we collect the location of your phone both when you post content to our service and otherwise, in order to show you more relevant posts and advertising. We do not share this location data with other companies.
Technical data: including internet protocol (IP) address, your login data, device references used for sending push notifications, information about operating system and version, time zone setting and location, device type and version, and other associated device type information required to access the app.
Usage data: including information about how you use our app and whether you have experienced technical issues such as app crashes.
Your posted content: We collect the images, location, and meta data you give us as part of using the services. This includes the quiz questions set in your post.
What does Globescoffing do with this data?
Globescoffing may use your personal data for the following purposes (legal processing grounds are shown brackets):
- Provide the requested products and services to you, including sending you notifications when you’ve won or lost points, or when there are new items in your feed (performance of a contract).
- Monitor traffic patterns and usage of the app to help improve the app design and layout (legitimate interest).
- Identify, troubleshoot and resolve any issues (legitimate interest).
- Provide customer service, including responding to your enquiries and fulfilling any requests (performance of a contract).
- Keeping a record of your relationship with us (legitimate interest).
- To generate aggregated or anonymised statistics for internal business purposes (legitimate interest).
- Analyse and profile personal data to evaluate certain things such as estimating how likely you are to be interested in products from us and our partners, and to personalise your experience of our app with more relevant screens, features or in-app messages, and send more relevant communications (legitimate interest).
- Send you important information about our products, services and other technical notices, updates, security alerts, and support and administrative messages (performance of a contract, legitimate interest, legal obligation).
- To enable you to participate in a prize draw, competition or complete a survey (legitimate interest, consent).
- Comply with legal obligations, and to establish, exercise, or defend against legal claims (legal obligation, legitimate interest).
Links to other websites and apps
Our app may contain links to the apps or websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Storing your information
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
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 legally required to do so.
Where we have given you, or where you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our website or app, you are responsible for keeping this password or PIN confidential. You must not share this password or PIN with anyone.
Outside the EEA
Transfers of data from the UK to the European Economic Area (EEA) is permitted by the UK government. Some of our external third parties are based outside the EEA so their processing of your personal data will 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:
- only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- using the International Data Transfer Agreement approved by the Information Commissioner’s Office which gives personal data the same protection it has in the UK.
Data retention
We will only keep 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, 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 and regulatory requirements.
Your rights
We will need to confirm your identity and ensure your right to access your personal data or to exercise any of the other rights listed below. We may also need further information from you in order to speed up your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed below), however we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We try to respond to all legitimate requests within one month, but occasionally this may take longer if your request is particularly complex, or you have made a number of requests (if this is the case, we will notify you and keep you updated).
Access to your personal data
You have the right to request access your personal data (commonly known as a data subject access request (SAR)). If you would like a copy of the information held on you, please contact us as outlined at beginning of this policy.
Correction of your personal data
You have the right to request the 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, although we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
Erasure of your personal data
You have the right to request the erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete 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.
Objection to processing of your personal data
You have the right to object to the 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.
Restriction of processing your personal data
You have the right to 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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Transfer of your personal data
You have the right to request the transfer of your personal data to you or to a third party. Subject to the rules and regulations that govern the products and services we provide, 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.
Withdrawing consent
You have the right to 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.
Contact the Information Commissioner’s Office
You have the right to contact the Information Commissioner’s Office (ICO) who are an independent body and complain to them if you are unhappy with how we have used your data.
The ICO’s details are:
- Postal correspondence: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline: 0303 123 1113
- Website: ico.org.uk
Changes to this Privacy Policy
We may make changes to this Privacy Policy, so please review it every now and then. If appropriate (and we have appropriate details) we will notify you by email about changes.