Data Policy
Introduction
Playground Social Ltd (the "Company", "we", "us" or "our") respects your privacy and is committed to treating any information that we obtain about you with as much care as possible and in a manner that is compliant with all applicable data protection legislation including the EU General Data Protection Regulation 2016/679 ("GDPR") and any national implementing laws in relation to the same including the Data Protection Act 2018 (collectively, "Data Protection Legislation").
If you have any questions about this privacy policy, please contact our support team by email at hello@playground-app.io.
This policy applies to your use of:our mobile application software known as Playground (App); and any of the services accessible through the App (Services). This policy sets out the basis by which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this data protection and privacy policy (the "policy") carefully. Among other things, it explains: what personal data we may collect about you in connection with: providing you with our App and the Services; your online interaction with us (including via the App and any social media channels, or by telephone or email); and any other interaction between you and us through any other channels related or ancillary to the foregoing,(collectively, the "Channels"); how we collect, store, disclose, transfer, protect and otherwise process that personal data (and for what purposes); and other important information, such as the lawful basis or bases by which we process your personal data, how long we retain your personal data, and the rights you have in relation to the personal data we hold about you.
This policy supplements (and its terms apply in addition to) any other terms of use or other terms and conditions agreed between you and the Company from time to time, including our App T&Cs. In this policy, terms defined in the GDPR, including "data subject", "personal data", and "processing", have the same meaning when used in this policy. The words "include", "including", "such as" and similar words and phrases shall be construed to mean "including without limitation".
This policy is intended to be communicated to you in a concise, transparent, intelligible and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email hello@playground-app.io and we will endeavour to respond as soon as possible.
The Company reserves the right to make changes to this policy from time to time including as may be necessary or desirable to reflect any changes in: (i) the ways in which we gather and process personal data; (ii) Data Protection Legislation; or (iii) best practice. The Company will endeavour to notify you of such changes but you are advised to check for an updated version of this policy via the App each time you interact with us through the Channels.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 your relationship with us.
The personal data we process
We collect personal data about you through the Channels when you: send messages via the App (which includes your location data) or otherwise interact with other users of the App or venues listed on the App; register for an account to use our App or access the Services, or subscribe for or participate in other services, competitions, contests, special events, or our mailing list; contact us (whether in writing, by email, by telephone or otherwise), including via any contact form available on the Channels; make any enquiry or application with respect to careers, vacancies or opportunities at the Company (this personal data may be subject to a separate privacy policy for applicants, which will be notified to you); purchase, request or subscribe for the Services; request technical support or other customer care support; participate in polls, surveys and questionnaires on or related to the Channels; post content on our social media pages or other Channels which provide for user-generated content; and otherwise interact with us through the Channels.
The type of personal data we process may include (if and as applicable):information you voluntarily provide through use of the App and profile creation such as your photo(s), display name, age, gender, geo-location data and any images and other information collected from your device’s camera and photo(s) when uploading photo(s) from your camera roll to the App (“Profile Information”); identity and contact information, such as your name, user name, email address, postal address, date of birth, telephone number and other information provided by you when you register for an account on our Channels or subscribe for other services, contests, special events or our mailing list ("Identity and Contact Data"); information which you provide in any correspondence with us ("Correspondence Data"); if you enquire or apply for any vacancies or opportunities at the Company, your CV, résumé, educational background, employment history and any other information you provide in connection with the same ("CV Data"); in relation to any order, purchase or subscription made by you, your order details, payment information, preferences and other transaction information provided or obtained in connection with any service you have requested, bought or subscribed for ("Service Data"); your responses to any polls, surveys and questionnaires we may run from time to time ("Response Data"); marketing and communications data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences ("Marketing and Communications Data"); information about how you use the App, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you're using and have last used the App (“User Use Data”); information about the people, accounts, you are connected to and how you interact with them across our App; information if you choose to upload, sync or import it from a device, which we use for things like helping you and others find people you may know; information about your activity through the Services (for example, we may collect information about: how you interact with the Services, how you communicate with others such as their names, the time and date of your communications, the number of messages you exchange with your friends, which friends you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot)); device phonebook; (“Network Data”); location related information, such as your current location, the places you like to go, and the businesses and people you are near to in order to provide, personalise, contextualise and improve our App including ads for you and others (“Location Data”); and any personal data contained in content you post on our social media pages or otherwise through posting any user-generated content ("User-Generated Data").
We do not process: any special categories of personal data (including 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); any information about criminal convictions and offences; or any information about children under the age of 13, and you should not provide us with any such information through any of the Channels.
The purposes for which we process your personal data
We use the personal data referred to in paragraph 2 above for the purposes of (if and as applicable): personalising content on the Channels;sending you promotional and marketing materials, notifications, updates and exclusive news (with your consent, where necessary); providing you with access to our App and the Services; processing payments and fulfilling orders (if and as applicable); internal training and other internal uses to improve the Services and user experience (including improving our marketing and promotional efforts, analysing channel usage statistics, improving content and customising the content and layout of our Channels); responding to any correspondence from you including enquiries, comments, complaints and request for technical assistance; if your data was provided in connection with a career opportunity or vacancy, assessing your fitness and eligibility for any particular role; administering any polls, services, questionnaires, competitions, contests, or special events which you may have subscribed for or participated in; recording your purchase or usage history and administering your account with us;market research and demographic studies; complying with any legal obligation; and otherwise carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose (including as may be provided for in any terms of use governing our App or any other arrangement between us).
We may process your personal data for the purposes set out in paragraph 3.1 ourselves or in conjunction with our third party service providers (in accordance with paragraph 6).
The lawful bases by which we process your personal data
Consent
Generally, we do not rely on consent as a legal basis for processing your personal data. Occasionally, however, we will get your consent: before sending third party direct marketing communications to you (e.g. via email or text message); for processing data with special protections; or for processing data which you allow us to receive through the device-based settings you enable (such as access to your GPS location, camera or photos), so we can provide the features and services described when you enable the settings.
If this policy has been communicated to you in relation to any such communications or processing and you have consented to the same, then by accepting the terms of this policy, you give the Company your express, freely given consent to process any of your personal data in accordance with the terms of this policy.
Where you have consented to our processing of your personal data, you may withdraw your consent at any time by contacting hello@playground-app.io. You can also unsubscribe from different types of emails by following the unsubscribe link displayed at the bottom of each email. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds as set out below.
Other lawful grounds
The Company may process your personal data in any circumstances where such processing is necessary:in order to perform any agreement between us (including pursuant to our any terms of use governing our App or any other arrangement between us); to comply with any applicable law or regulation; or for the purposes of the legitimate interests pursued by us or third parties. These legitimate interests include the purposes identified above in paragraph 3.1 but also include other commercial interests and our internal administrative purposes.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. More information about which lawful basis is used for which data processing activity is set out below:
To install the App and register you as a new App user: Your consent; Performance of a contract with you
To process in-App purchases and deliver Services including managing payments and collecting money owed to us: Your consent; Performance of a contract with you; Necessary for our legitimate interests (to recover dents due to us)
To provide, personalise and improve the Services: Performance of a contract with you; Legitimate interest (to develop the Services, improve user accessibility and tailor the user experience)
To promote safety, integrity and security: Performance of a contract with you; Legitimate interest (to provide security of the App)
To communicate with you, for example, on issues relating to the Services: Performance of a contract with you; Legitimate interest (to promote customer care)
To process and deliver any orders, subscriptions, or requested services including (a) Manage payments, fees and charges (b) Collect and recover money owed to us: Performance of a contract with you; Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use the Services)
To enable you to partake in a prize draw, competition or complete a survey: Performance of a contract with you; Necessary for our legitimate inyterests (to study how customers use the Services, to develop them and grow our business)
To administer and protect our business and this App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data): Necessary for the legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation
To deliver relevant App content and advertisements to you and measure or understand the effectiveness of the adverting we serve to you: Necessary for our legitimate interests (to study how customers use the Services, to monetise them, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our App, and Services, marketing, customer relationships and experiences: Necessary for our legitimate interests (to define types of customers for the Services, to keep our App updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you: Necessary for our legitimate interests (to develop the Services and grow our business)
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What if you refuse to provide us with any personal data?
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested (or fail to consent to the processing of that data, if necessary), we may not be able to perform the contract or arrangement we have or are trying to enter into with you (for example, to provide you access to the App or Services). In this case, we may have to cancel a service you have with us but we will endeavour to notify you if this is the case at the time.
Whilst we may be able to provide you with some of the Services notwithstanding your refusal to submit personal data, this may limit your ability to participate in some activities, or use certain features, services or functionality.
Sharing information with affiliates and third parties
We will not share any of your personal data with third parties except as set out in this paragraph 6 or otherwise notified to you or agreed between you and us from time to time. The App is a social networking platform that is designed to allow users to share information. Information which you make available (either publicly or to a select user or group of users of the App) may therefore be shared, according to your use of the App and who you decide to share certain data with, with other members on the App. This may include information about how you have interacted with the Services, the names of who you are connected with on our App; information relating to whether you are active on the App, including whether you are currently active; and other information that will help the app users understand your connections with others using the same App. We share data when you share and communicate data using the App with other people or businesses, those people and businesses can see the content you send. From time to time, we will also need to share personal data with the following types of third party service providers who we engage to provide services which facilitate our business and who may need to process your personal data to the extent necessary to provide those services: Mixpanel User Analytics, our service provider for tracking user interactions, partnered places, advertising companies; and any similar or replacement third parties from time to time. We may explicitly ask if you would like us to share your information with other third parties who are not described elsewhere in this policy. We seek to ensure that any third party engaged by us who processes your personal data in connection with the purposes listed above has policies and procedures in place to ensure compliance with the Data Protection Legislation.
For any third parties that are based, or process data, overseas, we only engage such third parties in accordance with paragraph 7.
Unless otherwise disclosed to you from time to time, we will remain the data controller in respect of your personal data notwithstanding that third parties may be engaged as data processors. We may also share your personal information with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws, any terms of use governing our App or any other arrangement between us, or any usage guidelines for specific services, or threaten the rights, property, or safety of our Company, our users, or others)
International transfers of personal data
From time to time it may be necessary for us to transfer your information internationally. In particular your information may be transferred to and/or stored on the servers of our Affiliates or other third parties identified in paragraph 6 which are based outside of the EEA.However, we will not transfer your personal data outside of the EEA unless: such transfer is to a country or jurisdiction which the EU Commission has approved as having an adequate level of protection (including to the USA where Privacy Shield compliant); appropriate safeguards are in place as set out in Article 46 GDPR or equivalent provisions of other Data Protection Legislation; or the transfer is otherwise allowed by applicable Data Protection Legislation (such as in the form of a derogation under Article 49 GDPR).
Your rights as a data subject
Subject to any conditions or requirements set out in the relevant Data Protection Legislation, you may have some or all of the following rights in relation to the personal data we hold about you: the right to request a copy of your personal data held by us;the right to correct any inaccurate or incomplete personal data held by us. You can deactivate your account, or amend any personal data which cannot be modified online, by emailing us at hello@playground-app.io; the right to request that we erase the personal data we hold about you; the right to request that we restrict the processing of your data; the right to have your personal data transferred to another organisation; the right to object to certain types of processing of your personal data by us; and the right to complain (please see paragraph 12 of this policy).
Please note however that these rights are not absolute in all situations and may be subject to conditions and provisos set out in relevant Data Protection Legislation. The Company cannot therefore guarantee that any request from you in connection with the rights set out above will be agreed to. For further information, or to see if you can exercise any particular right, please contact us at hello@playground-app.io.
Storage and retention of your personal data
As a minimum, we need to store your data for as long as is necessary to enable us to provide you with the access to our App and Services that you have requested from us (or to support your other uses of our Channels, such as maintaining your account(s)).
However, we will retain certain of your personal data for longer if we think it is reasonably necessary to do so in the circumstances, taking into consideration factors such as: our need to perform any agreements between you and us (including pursuant to the App’s terms of use); our need to answer any queries or resolve any problems you may have; your continued consent to receive marketing and other emails and communications from us; our continued provision of the Services to you; and our need to comply with legal requirements (e.g. relating to record keeping). If you tell us that you would like to delete your account, we will take steps to delete all the personal data we hold about you once it is no longer necessary for us to hold it (e.g. to fulfil any outstanding orders, resolve disputes, or as is permitted by applicable law or regulation). For as long as we do store your data, the Company follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided.
All information you provide us is stored on Amazon Web Services (AWS) in Ireland. AWS employs a high level of data protection safeguards, more information of which can be seen here: https://aws.amazon.com/blogs/security/all-aws-services-gdpr-ready/.
The Company has security measures in place designed to protect against the loss, misuse, and alteration of the information under our control.
If you let us use your information, you can always change your mind and simply revoke your permission by changing the setting on your device if your device offers those options. Of course, if you do that, certain services may lose full functionality.
Notwithstanding our efforts to keep your personal data secure, no system can be 100% reliable. To the fullest extent permitted by law, we cannot be held liable for any loss you may suffer if a third party procures unauthorised access to any data you provide through the Channels.
In addition, you are responsible for maintaining the strength and confidentiality of any login credentials. We will notify you as soon as reasonably practicable if we have reason to believe that there has been a personal data breach by us which could adversely affect your rights and freedoms.
Links to third parties
Our App may contain links or redirections to other websites or mobile applications that are beyond our control. Such links or redirections are not endorsements of such websites/mobile applications or representation of our affiliation with them in any way and such third party websites or mobile applications are outside the scope of this policy.
If you access such third party websites or mobile applications, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website or mobile application operated by any third party.
Our App uses some or all of the following tracking technologies:
Strictly necessary tracking technologies
These are tracking technologies that are required for the operation of our App. They include, for example, tracking technologies that enable you to log into secure areas of our App, use a shopping cart or make use of e-billing services.
Analytical/performance tracking technologies. These allow us to recognise and count the number of users and to see how users move around our App when they are using it. This helps us to improve the way our App works, for example, by ensuring that users are finding what they are looking for easily.
Functionality tracking technologies
These are used to recognise you when you return to our App. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting tracking technologies
These tracking technologies record your use of our App, the pages you have visited and the links you have followed. We will use this information to make our App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Device tracking technologies
Each time you visit our website or use our App we will automatically collect personal data including device, Content and Usage Data such as: information relating to the operating system, hardware and software versions, battery level, signal strength, device memory, available storage space, app and file names and types and plugins; unique identifiers, device IDs, mobile phone number, and other identifiers, such as from games, apps or accounts you use; Bluetooth signals, and information about nearby Wi-Fi access points, beacons, and cell towers service provider and signal strength; information you allow us to receive through device settings you turn on, such as access to your GPS location; some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose.
You can withdraw your consent at any time by disabling Location Data in your settings; information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed; and information from device sensors, such as accelerometers, gyroscopes, compasses, microphones and headphone connection.
Please note third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use tracking technologies (e.g. web beacons), over which we have no control.
Your browser may give you the ability to block all or some tracking technologies by activating a setting in your browser's options. However, if you use your browser settings to block all tracking technologies (including essential tracking technologies) you may not be able to access all or parts of our Channels.
Questions and complaints
For all questions or complaints about this policy, we would appreciate the chance to deal with your concerns before you approach the relevant data protection authority. Please contact us in the first instance via email at hello@playground-app.io
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner's Office (ICO) (www.ico.org.uk).