Privacy Policy – TDT App

Last updated: 10 June 2020

EA Worldwide Acquisitions Limited (we) are committed to protecting your personal data and respecting your privacy.

This policy (together with our end-user licence agreement [TDT APP END USER AGREEMENT] (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

TDT mobile application software (App) available on Apple AppStore and Google PlayStore (App Site), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device); and
any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [tdt-app.com/privacy-policy].

[IMPORTANT INFORMATION AND WHO WE ARE]

[THE DATA WE COLLECT ABOUT YOU]

[HOW IS YOUR PERSONAL DATA COLLECTED?]

[HOW WE USE YOUR PERSONAL DATA]

[DISCLOSURES OF YOUR PERSONAL DATA]

[INTERNATIONAL TRANSFERS]

[DATA SECURITY]

[DATA RETENTION]

[YOUR LEGAL RIGHTS]

[GLOSSARY]

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]

Important information and who we are

EA Worldwide Acquisitions Limited is the controller and is responsible for your personal data (collectively referred to as “EA”, “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

Full name of legal entity: EA Worldwide Acquisitions Limited
Name or title of data privacy manager: Lily Kostadinova
Email address: enquiries@thedevelopmenttank.com
Postal address: Suite 3.05, 3^rd Floor, 111 Buckingham Palace Road, London, SW1W 0SR
Telephone number: 07580 330508

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 the App is downloaded outside the UK.

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 27/05/20. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS, by email or when you next start the App or log onto your account. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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.

Third party links

Our Services 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. 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 as follows:

Identity Data.
Contact Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.

We explain these categories of data in the “Description of Categories of Personal Data” below.

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 Data, Contact Data and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, by corresponding with us (for example, by email), or sending us contents and materials to upload onto our Services. It includes information you provide when you register to use the App, subscribe to any of our Services, or enter a competition, promotion or survey and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you use the App and Services we will automatically collect personal data including Device Data, Content Data and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [COOKIE POLICY] for further details.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
Device Data from analytics providers such as Google based outside the EU; and
[Contact Data] from providers of [technical services] such as [eStream Inc based outside the EU].

We use cookies to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App or use the Services and also allows us to improve the App and the Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [COOKIE POLICY].

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 we need to perform a contract we are about to enter or have entered with you (such as our EULA 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.

To find out more about the types of lawful basis that we will rely on to process your personal data, see the Glossary below.

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

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new App user	Identity Data Contact Data Device Data	Your consent
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Data Contact Data Profile Data Marketing and Communications Data	Your consent Performance of a contract (such as our EULA) 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 and EULA)
To enable you to participate in a prize draw, competition or complete a survey	Identity Data Contact Data Device Data Profile Data Marketing and Communications Data	Your consent Performance of a contract (such as our EULA) 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 and the App including troubleshooting, data analysis and system testing	Identity Data Contact Data Device Data	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content to you, including uploading content or material your contribute to our Services To monitor trends so we can improve the App (e.g., to monitor how often content is accessed and how often you use our App and Service)	Identity Data Contact Data Device Data Content Data Profile Data Usage Data Marketing and Communications Data	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

We will not transfer your personal data to any third party.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data security

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 our Service, you are responsible for keeping this password 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.

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.

Data retention

We will keep basic information about you (including Contact Data and Identity Data) for 30-days after your user account (whether an administrative account or not) has expired. In the event that you do not use the App for a period of 15-consecutive days then we will treat your account as expired. However, we will continue to keep and use any content contributions you have made pursuant to your EULA unless the legal basis pursuant to which we are using any personal data within that content contribution no longer applies.

In some circumstances you can ask us to delete your data: see “Your Legal Rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

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

Please click on the links below to find out more about these rights:

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 enquiries@thedevelopmenttank.com.

Glossary

Lawful basis

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. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

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. An example of such contract is your EULA.

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.

Your legal rights

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:
- 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.
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.

Description of categories of personal data

Identity Data: first name, last name, username or similar identifier title.
Contact Data: email address and telephone numbers.
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), and mobile network information.
Content Data: includes information stored on your Device, including login information, and photos, videos or other digital content.
Profile Data: includes your username and password your preferences, feedback and survey responses.
Usage Data: includes details of your use of the App or the Service including, but not limited to, traffic data and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.