1.1 R-CAP is published and operated by Tronix Software Solutions Ltd, a limited company registered in England and Wales (referred to as “we”, “us” and “TRONIXSS”) and we are committed to protecting and respecting your privacy when using any application published by us.
2. SCOPE OF POLICY
(a) any mobile application software published by us under the name “R-CAP” (together the “Application”) hosted on any appstore from time to time available now or in the future (together the “AppExchange”); and
(b) any of the services accessible through the Application from time to time (the “Services”).
2.2 This policy sets out the basis on which any personal and non-personal information we collect from you, or that you provide to us, will be processed by us. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy. By agreeing to this policy, you give a number of express consents as detailed herein.
2.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading the Application onto a mobile device or personal computer (each a “Device”) you consent to the collection, storage and processing of your personal information as stated in this policy.
For the purpose of the Data Protection Act 1998, the data controller is Tronix Software Solutions Ltd a limited company incorporated and registered in England and Wales with company number 09339264 whose registered office is at Apartment 612 122 East Ferry Road, London, E14 9ET which is registered with the Information Commissioner’s Office with registered number [ZA201338].
3. INFORMATION WE MAY COLLECT FROM YOU
3.1 We may collect and process the following personal and non-personal data about you:
(a) Account information: information you provide when you register to use the Application and subscribe to use any of the Services. This will include your email address, password, username and mobile phone number.
(b) Correspondence: information you may provide by filling in forms on the Application, or by corresponding with us (for example, by e-mail, chat or by telephone) for feedback, support or general enquiries. The information you give us may include your name, address, e-mail address and phone number, the Device’s unique device identifier, age, username, password and other registration information, personal description and photograph. If you contact us, we may keep a record of that correspondence.
(c) Information we collect about you and your Device: Each time you use our Application we may automatically collect the following information:
(i) technical information, including 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 and time zone setting;
(ii) details of your use of our Application including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
(d) Information we receive from other sources: We work closely with third parties including, for example, business partners, sub-contractors in technical, advertising networks, analytics providers and search information providers.
(e) Unique application numbers: when you install or uninstall the Application or a Service containing a unique application number or when the Application searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
3.2 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
3.3 Please note that you are under no obligation to provide any information (other than login information necessarily required) when you use the Application. In particular you have no obligation to complete all information in any profile form. Please note that any information you provide in a profile form will be published on your profile and will be viewable to other users of the Application.
4.1 Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your Device. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Application.
4.2 The data collected by cookies is anonymous. You can delete all cookies that are already on your Device’s hard drive by searching for files with “cookie” in it and deleting them. In addition, if you want to stop cookies from being stored on your Device, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Application. For more information about cookies, please visit: www.allaboutcookies.org
4.3 Web beacons consist of a small string of software code that represents a graphic image request on a page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalisation. Web beacons used by the Application collect only anonymous data.
4.4 In order to improve the Application and the Services we offer you, we may use (temporary and persistent) cookies, authorised third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Application.
4.5 In order to understand how people use the Application and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed pages, referring/exit pages, Application type, date/time stamp information and details like the number and location of cursor clicks on a given page, cursor movements, scrolling activity and the search words you use while being on and using the Application.
5. USES MADE OF THE INFORMATION
5.1 We use the information we collect about you (including your personal data) so that we can improve the Application and better customise it to meet your needs. We also use the information we collect about you to resolve disputes, troubleshoot problems, and enforce our Terms.
5.2 We may use third-party advertising companies to serve advertisements when you use the Application. These companies may use information about your use of the Application and other websites in order to provide advertisements about goods and services of interest to you. This information does NOT include your contact information or other personal information.
5.3 We shall never use your personal information when posting on a third-party website unless we have your prior written consent.
5.4 We may use your personal information for the following purposes:
(a) to manage and administer the Application and the Services;
(b) to identify when you log into your Account on different Devices;
(c) to improve your browsing experience by personalising the Application;
(d) to enable you to use the Application;
(e) to send you newsletters and other communications we think you may find relevant or which you have requested from us (including notifying you about changes to the Application or our Services);
(f) to deal with enquiries, complaints, and feedback from you;
(g) to provide third parties with statistical anonymised information about our users;
(h) to send you emails offering you to take part in a survey and/or give feedback; and
(i) to analyse and improve the Services offered on the Application.
5.5 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
6. Disclosure of your information
6.1 We may disclose your personal information to any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
6.2 We may disclose your personal information to third parties:
(a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(b) if TRONIXSS or substantially all of its business and assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
(c) if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
(d) if we are requested or required to do so by any judicial or law enforcement agency for the purposes of prevention or prosecution of any criminal offense and /or terrorist activity. We shall not be required to insist that the relevant judicial authority or law enforcement agency secures a court order requiring us to disclose the relevant information.
(e) in order to:
(i) enforce or apply the Terms and other agreements or to investigate potential breaches; or
(ii) to protect the rights, property or safety of R-CAP and TRONIXSS, its users, staff and related third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. Where we store your personal data
7.2 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Application. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
8. Your rights
8.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
8.2 Our Application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Application or the Services are advertised). If you follow a link to any of these websites, 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.
9. Access to information
9.1 The legislation governing collection and use of personal data by us gives you the right to access information held about you. Your right of access can be exercised in accordance with that legislation. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.
10. Compliance with legislation
10.1 We comply with the requirements of applicable legislation as follows:
(a) personal data shall be processed fairly and lawfully. We will ensure that data is obtained fairly, and will make reasonable efforts to ensure that data subjects are told who the data controller is, what the data will be used for, for how long the data will be kept and any third parties to whom the data will be disclosed. In order for processing to be fair and lawful, data which is not sensitive personal data will only be processed by TRONIXSS if at least one of the following conditions, set down in the Data Protection Act 1998, has been met:
(i) personal data shall be obtained only for a specified and lawful purpose or purposes, and shall not be further processed in any manner incompatible with that purpose or purposes;
(ii) TRONIXSS will ensure that data which is obtained for a specified purpose is not used for a different purpose, unless that use is done with the consent of the data subject, is covered by TRONIXSS’ registration with the Information Commissioner;
(iii) personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed. We will not collect personal data which are not strictly necessary for the purpose or purposes for which they were obtained;
(iv) personal data shall be accurate and, where necessary, kept up to date. We will take reasonable steps to ensure the accuracy of personal data which it holds, and will take steps to correct inaccurate data when requested to do so by a data subject;
(v) personal data processed for any purpose shall not be kept for longer than is necessary for that purpose. We will ensure that personal data are not kept for longer than is required by the purpose or purposes for which the data were gathered. We may retain certain data indefinitely for research purposes (including historical or statistical purposes), as permitted under applicable legislation, subject to the conditions laid down in the legislation for this type of processing;
(vi) personal data shall be processed in accordance with the rights of data subjects under applicable legislation. We will ensure that personal data is processed in accordance with the rights of data subjects under applicable legislation. These rights include the right to appropriate technical and organisational measures shall be taken to prevent the unauthorised or unlawful processing of personal data and the accidental loss, destruction of or damage to personal data; and
(vii) We will take steps to ensure the security of personal data which is held electronically and in manual form, to prevent the unauthorised disclosure of data to third parties, and loss or damage to data that may affect the interests of data subjects. We will also ensure that data processors provide an appropriate level of security for the personal data which they are processing on TRONIXSS’ behalf.