We use your data to provide the Notifi service to you, to promote the service, and for the purposes of running our business.
We share limited personal data with service providers outside of Europe, but this is subject to appropriate safeguards which require them to treat your personal data as if it were subject to European data protection rules.
If you are an Individual user, and you want to know how the owner of a group of which you are a member uses your personal data, you will need to contact the owner of the group. This policy deals with our use of your data only.
We are happy to answer your questions about any of this, email us at firstname.lastname@example.org
Who we are
Skygenapps Ltd collects uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
When we refer in this policy to ‘Businesses’, we are referring to an individual or entity who uses Notifi to set up and manage communication with individuals.
The personal information we collect from you
We collect the following personal information when you provide it to us.
- Business Registration Information: If you register as a Business, you will be asked to provide your first and last name, business name, email address and password on registration.
- Individual Registration Information: If you are an individual user, you will be asked for your first and last name, email address, mobile phone number and password on registration.
- Profile Information: as a business or individual user you can complete your Notifi profile. You may provide personal images and website and social networks you wish to link to your Notifi profile. You may also add or change your mobile phone number.
- Group Information: any personal information contained in details of the Notifi group name and description groups that you as a business user administer or are a member of.
The personal information we receive from others about you
Notifi Business User: We collect the following personal information when Businesses provide it to us.
- Group Invites: Your mobile number OR email address may be provided by the business user by means of Notifi when you are added to a Group
- Group Invites Bulk: Your mobile number and/or email address may be provided by the business user to a data processor at Skygenapps who uploads members en masse to the business user’s group as part of the Group Management service, this is subject to a Data Processing Agreement between us and the business, the terms of which can be found here.
Facebook: If as a Business or Individual user you register or log in to Notifi using a Facebook login, you are granting permission to Facebook to share your user details with us. This consists of your age, gender, email, first name, last name, and an application-specific Facebook id which will then be used to form a Notifi identity for you. If you remove the Notifi app from your Facebook settings, we will no longer have access to your information, but we will still have the information that we received when you first signed up for a Notifi account using Facebook.
Stripe: As a Business User you may use Notifi to register or connect to a Stripe account and we receive an application-specific Stripe ID that we associate to your Notifi Business Account.
Firebase: As a Business or Individual user you may supply your telephone number to Notifi. This is sent to Firebase (part of Google) phone verification service. If you correctly enter the verification code sent to your device then we associate the success application-specific Firebase ID and the telephone number to your Notifi account.
How we use your information
We are required to tell you what uses we make of your information, and the legal basis for our doing so. References in this section to the basis of processing (e.g. “Basis: Legitimate Interest”) are a reference to basis specified in General Data Protection Regulation under which we undertake the processing in question, as follows:
Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure Notifi 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 between us and you (for example, to provide you with a connection to another Notifi user you have requested under our terms of service) or to take steps at your request before entering into such a contract.
We use your information in the following ways:
|Business Registration Information||We use this to create a Notifi Business Account. We also use it to email you about your account or changes to the app.||Legitimate Interest;Performance of Contract|
|Individual Registration Information||We use this to create a Notifi Individual Account. We also use it to email you about your account or changes to the app.||Legitimate Interest; Performance of Contract|
|Profile Information||If you are a business this is used to display your business profile to the members of your group. If you are an individual this is used to display your profile to the owner of the group you belong to.||Legitimate Interest|
|Group Information||We use this to publish details about a Group that you create, have joined or have been asked to join.||Legitimate Interest;|
|Group Invites||We use this to link you to a group you have been invited to join.
The app sends, under the control of the business user, an invite by means of an SMS or email and, (under the control of the app) an in-app invite is also created.
When you first download the app and you have outstanding in-app invites then you will be automatically enrolled to these groups, otherwise you are already a Notifi user and you will be required to accept the in-app invites to join the groups. The business user will have had prior agreement from you to use your personal data to add you to their group.
|Performance of Contract|
|Group Invites Bulk||We use this to link you to a group you have been invited to join and we will email, if provided, to tell you that you have been added to a group.
The app creates an in-app invite. When you first download the app and you have outstanding in-app invites then you will be automatically enrolled to these groups, otherwise you are already a Notifi users and you will be required to accept the in-app invites to join the groups.
|We use this if you elect to register and login by using your Facebook account.||Legitimate Interest|
|Stripe||We use this to enable you to take payments and have those payments attributed to your Stripe Account.||Legitimate Interest; Performance of Contract|
|Firebase||We use this to ensure the phone number belongs to you and the device you are currently using.
If you are an individual user and do not successfully verify we do not allow you to use Notifi.
If you are a business user and do not successfully verify we do not associate that number to your profile.
|Legitimate Interest; Performance of Contract|
|Email to Customer Services||If you get in touch with us, we will record the fact that you have contacted us and may retain the content of your communication, together with your contact details and our responses. We use this to help us to deliver the Notifi service to you and answer your questions.||Legitimate Interest; Performance of Contract|
Additionally, we will use your personal data to administer and protect our business and the Notifi app (including making or defending any legal claims). This is in our legitimate interest.
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognises that cookies.
Types of Cookies
There are two broad categories of cookies:
First Party Cookies served directly by us to your computer or mobile device. They are used only by us to recognise your computer or mobile device when it revisits our site.
Third party cookies, which are served by a service provider on our site and can be used by the service provider to recognise your computer or mobile device when it visits other sites. Third party cookies are most commonly used for platform analytics or advertising purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are ‘permanent cookies,’ meaning that they survive after your browser is closed. They can be used by the site to recognise your computer or mobile device when you open your browser and browse the Internet again.
What cookies do we use?
Our website uses the following cookies:
|Type of cookie||Purpose|
|Google Analytics Cookies||We use Google Analytics software to monitor the number of people visiting the Notifi website, which uses a cookie to collect this information. Google Analytics only collects anonymous aggregate data, i.e. we cannot tell who you are or link data back to a specific username, and everyone’s data is shown as a whole, not individually. We use this only for statistical purposes to tell us information like how many people are new to the site or have visited before and which pages are the most popular.|
How to control or delete cookies
You have the right to choose whether or not to accept cookies and we have explained how you can exercise this right below. However, please note that if you do not accept our cookies, you may experience some inconvenience in your use of our site.
- You can set your cookie preferences by changing your browser settings so that cookies from this site cannot be placed on your computer or mobile device. In order to do this, follow the instructions provided by your browser (usually located within the “help” “tools” or “Edit” facility).
Who we share your personal information with
We use a number of partners to help us power Notifi, and some of them are used to process personal data:
- We use Microsoft Azure to securely store your personal data.
- We use Microsoft Azure to provide our bulk upload service for Businesses, which allows us to add members en masse to your groups. This process also uses Azure to produce reports on the success or failure of the upload.
- We use Microsoft Azure to produce reports on Business and Individuals that have registered on our App so that we can email them with important updates such as changes to Terms.
- We use Mailchimp to send out some of our email communications in respect of the Notifi service.
- We use Firebase, (part of Google) to help us gather statistics about app usage patterns on an this is on an anonymised basis that does not involve the processing of any data which personally identifies you.
- We use Firebase to help us verify phone numbers by sending an SMS message to your device. This involves us sharing your phone number with Firebase.
- We may share personal data with our developer if necessary to resolve a technical support question. Our developer is SABE Interactive Ltd, their website is at https://www.the-app-developers.co.uk/
- We pass your email address to Stripe, the payment service provider integrated into the Notifi app, to facilitate their providing payment processing services to Businesses.
- We use Google Analytics to gather web usage and aggregate data, on an anonymised basis that does not involve the processing of any data which personally identifies you.
- We may also share your personal information:
- When you agree to the sharing;
- When we are required to provide information in response to a legal requirement;
- When we believe it is necessary in order to prevent or respond to fraud, defend Notifi against attacks, or protect the property and safety of us, our users, or the public;
- If we merge with or are acquired by another company, sell the app, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner.
How long your personal information will be kept
We will retain your other data for a period of 12 months after your last interaction with the App. Until then, we consider you to be an active user, and will not delete your Notifi account unless you request us to do so.
We retain your personal data for longer if we need to in order to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, and keep Notifi secure and free from fraud and misuse.
Persons Under the Age of 18
Notifi is not intended for those under 18 years of age. No one under age 18 is permitted to provide any personal information on Notifi. We do not knowingly collect personal information from people under 18 years of age.
Transfer of your information out of the EEA
We use a number of service providers to help power Notifi. Some of these are based in the USA.
They are: Firebase (owned by Google), who we use to verify phone numbers; Mailchimp, our email service provider; and Microsoft Azure who provide us with hosting and reporting services.
We also transfer personal data to Stripe, (the payment processor integrated with Notifi) to process payments.
The USA does not have the same data protection laws as the United Kingdom and European Economic Area. Whilst the European Commission has not given a formal decision that the USA provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information to Firebase, Mailchimp, Microsoft Azure and Stripe will be subject to appropriate safeguards as permitted under the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. These include each of those companies’ Privacy Shield certifications. You can learn more about the EU-US Privacy Shield here – https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email us at email@example.com
- let us have enough information to identify you,
- let us know the information to which your request relates, including any account or reference numbers, if you have them.
If you would like to unsubscribe from any promotional material we send you, you can click on the ‘unsubscribe’ button at the bottom of the promotional emails, or email us at firstname.lastname@example.org
You cannot unsubscribe from non-promotional emails like the welcome email, email about updates to your account or where we have identified you as an account that will be deleted.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was last updated on the 9th of August 2018
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us please send an email to email@example.com