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Privacy Policy

Last updated 2nd January 2019

INTRODUCTION

Serelay Ltd (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the “Application”).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the application.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

 

1. WHAT INFORMATION DO WE COLLECT?

Information Automatically Collected

In Short: some information – such as IP address and/or browser and device characteristics – is collected automatically when you use our Application.

We automatically collect certain information when you visit, use or navigate the Application. This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Application and other technical information. This information is needed primarily needed to maintain the security and operation of our Application, and for our internal analytics and reporting purposes.

Information collected through our Application

In Short: We may collect information regarding your geolocation and other features of your mobile device when you use our app.

If you use our app, we may also collect the following

Geo-Location Information

We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access

We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, camera, microphone, sensors, storage and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data

Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, country, location, and any other data you choose to provide.

 

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations and/or your consent.

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:

  1. Verify the authenticity of photos and videos you capture through the Application
  2. Assist law enforcement and respond to subpoena.
  3. Compile anonymous statistical data and analysis for use internally or with third parties.
  4. Increase the efficiency and operation of the Application.
  5. Monitor and analyze usage and trends to improve your experience with the Application.
  6. Notify you of updates to the Application.
  7. Offer new products, services, mobile applications, and/or recommendations to you.
  8. Perform other business activities as needed.
  9. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  10. Process payments and refunds.
  11. Request feedback and contact you about your use of the Application.
  12. Resolve disputes and troubleshoot problems.
  13. Respond to product and customer service requests.
  14. Solicit support for the Application.

 

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

Shared by You – by File Transfer

When you share a media item (photo or video) captured by you through the Application with a recipient, you are providing the recipient with the capability to verify the content, time and location of this Media item. This third party will hence have access to the full metadata relating to this media item. If you would like to mask the granularity of this metadata we recommend sharing media through ‘snapshot’ functionality.

Shared by You – using ‘snapshot’ functionality

When you share a media item (photo or video) captured by you through the Application using the Application’s ‘snapshot’ functionality you are creating a public link sharing the content, time and location relating to the media item. You can then elect to alter the granularity by which time and location readings are shown.

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including data analysis, hosting services and customer service.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

 

4. DO WE USE THIRD PARTY MAPPING SERVICES?

In Short: Yes, we use Google Maps on Android and Apple Maps on iOS for the purpose of providing better service.

The Android version of our Application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By Using our Android Maps API Implementation, you agree to be bound by Google’s Terms of Service.

The iOS version of our Application uses Apple Maps APIs. You may find the Apple Maps Terms of Service here. To better understand Apple’s Privacy Policy, please refer to this link.

By Using our Apple Maps API Implementation, you agree to be bound by Apple’s Terms of Service.

 

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

 

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

 

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with the applicable data protection law.

Specifically in relation to (ii), you may trigger deletion of all of your personal data directly through the Application.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

 

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

 

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Application, you have the right to request removal of unwanted data that you publicly post on the Application. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Application, but please be aware that the data may not be completely or comprehensively removed from our systems.

 

10. CONTACT US

If you have questions or comments about this Privacy Policy you may email us at info@serelay.com or by post to:

Serelay Ltd
Atlas Building
Harwell Campus, Oxfordshire
OX11 0QS
United Kingdom

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SERELAY LIMITED
Atlas Building R27,
Harwell Science Park
OX11 0QX
United Kingdom

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