Important information and who we are

Alike is a CIO registered with the UK Charities Commission with charity number 1181848 and is the controller and is responsible for your personal data (collectively referred to as "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: Alike
• Data Privacy Manager
• Email address: privacy@alike.org.uk
• Postal address: Alike, Soho Works, 180 the Strand, London. WC2R 1EA.

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 the date at the top of this policy. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. 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 App 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, such as Contact and Location Data. 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.
• Transaction Data.
• Financial Data
• Device Data.
• Log Data
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data
• Special Category Data which may include information about your health such as information about the type and stage of cancer you may have and your treatment.
• Data contained in messages you send or receive (we are implementing end to end encryption technology and once implemented, these messages will be encrypted and we will have no access to them)

We explain these categories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW].

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We also collect Special Category Data about you. Mainly this will be about your health but it may include other data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions. We do not 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 you give us about you by filling in forms on the App or using the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to download or register an App, share data via the App's social media functions, details of your marketing and communications preferences, information provided when you enter a competition, promotion or survey, data when you use the messaging function of the App and when you report a problem or request support for our App, our Services, other users of the App. If you contact us, we will keep a record of that correspondence. This may also include telephone calls, emails and post. It may also include information we collect from you as a result of any monitoring which may take place. We may monitor (which may include recording) certain interactions between us in order to comply with any legal obligations, to detect fraud or criminal activity as well as for training purposes.

• Information we collect about you and your device. Each time you use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
• Location Data. We also use GPS technology to determine your current 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 we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Device Data from the following parties:

analytics providers such as Google and Apple based outside the EU;

search information providers such as Google based inside and outside the EU.

• Identity and Contact Data from social media services as part of our customer verification and anti-fraud measures
• Information from other users of the App or third parties if we receive any complaints about you (for example of harassment or sending inappropriate messages)
• Identity and Contact Data from publicly available sources such as internet searches; and
• Log in authentication for assisting in authenticating you such as Facebook or Google login .

Unique application and device numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates or when you agree to receive push notifications, that number and information about your installation, for example, the type of operating system, may be sent to us and used to send push notifications to your device.

Cookies

We do not use cookies on our App. Our website uses cookies to distinguish you from other users of our website and to remember your preferences. This helps us to provide you with a good experience when you use our website and also allows us to improve our website. 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 [LINK].

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. We will usually only ask for your consent to process Special Category Data (such as health data) or when we would like to provide marketing information to you (including information about other products and services). Without your consent, in some circumstances, we may not be able to provide you with and you may not be able to benefit from some of our services. Where you provide Special Category Data about a third party, we may ask you to confirm that the third party has provided his or her consent for you to act on their behalf.
• We will also ask for your consent when collecting and using information you allow us to receive through your device (such as access to your contacts and other Content Data, GPS location, camera, or photos), so we can provide the features and services described when you enable the settings.
• When we process data you provide to us based on your consent, you have the right to withdraw your consent at any time and to port that data you provide to us. To exercise your rights, see the How You Exercise Your Rights section of the Privacy Policy

• Where we need to perform a contract we are about to enter or have entered 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.
• Where we need to use your personal information to establish, exercise or defend our legal rights, for example when we are faced with any legal claim or where we want to pursue any legal claims ourselves

Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. We will not share any of your health or other Special Category Data with third party without your consent.

Purposes for which we will use your personal data

Disclosures of your personal data

We may disclose your personal data to third parties 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, if you have consented to this, to protect our rights and property and the rights, safety and property of others (provided we comply with data protection law).

We may also transfer your personal data to a third party we have appointed to provide services to us on our instructions which we refer to as External Third Parties as set out in the [Glossary].

We may transfer your data in connection with a potential transfer of part or all of our organisation. In such circumstances we may share information with prospective purchasers (for example as part of a controlled due diligence exercise). Alternatively, we may seek to acquire another organisation or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.

If we reorganise our business as we may need to transfer information about you to another member of our group so that we can continue to provide the Service to you.

International transfers

While we do not routinely transfer your personal data outside the European Economic Area (EEA) should we do so, we will only do this as permitted by data protection legislation.

Data security

All information you provide to us is stored on secure cloud servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App, 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 will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

Certain Services include social networking, chat room, messaging or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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 only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law. Further details of our data retention policies can be obtained by writing to the address above.

In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law. Further details of our data retention policies can be obtained by writing to the address above. We are implementing end to end encryption for our messaging service and once this is enabled we will delete any of your user to user messages that we process so as to improve privacy of your messages.

We will not keep your personal information longer than is reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply or demonstrate compliance with our legal and regulatory obligations. Where we can, and it is appropriate, we will minimise personal data or de-personalise data to use for statistical or analytical purposes.

In some cases, such as if there is a dispute or a legal action affecting the information we may need or be required to keep personal information for longer.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data for at least 6 years.

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.

In the event that you do not use the App for a period of time then we may treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under GDPR (prior to 31 December 2020 and the Data Protection Act 2018 from 1 January 2021) in relation to your personal data.

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

• [Request access to your personal data.]
• [Request correction of your personal data.]
• [Request erasure of your personal data.]
• [Object to processing of your personal data.]
• [Request restriction of processing your personal data.]
• [Request transfer or your personal data.]
• [Right to withdraw consent.]

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 privacy@alike.org.uk or Postal address: Alike, Soho Works, 180 the Strand, London. WC2R 1EA.

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 organisation 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. Your usage of the App and us making it available to you is a contract between us

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.

Third parties

External third parties

Service providers acting as processors based in the United Kingdom, who provide IT and system administration services primarily Amazon using Amazon Web Services and Google.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, regulators (such as the Charities Commission) and insurers based in the UK who provide services to us.

Web developers who are engaged to write our software. We will minimise any access they have to your personal data.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK.

Marketing and other agencies that we may appoint.

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:

1. if you want us to establish the data's accuracy;

2. where our use of the data is unlawful but you do not want us to erase it;

3. 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

4. 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.

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.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Description of categories of personal data

• Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, gender, other biographical information you provide, your photographs.
• Contact Data: addresses, email addresses and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-App purchases or donations.
• 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), mobile network information, your device operating system, the type of mobile browser you use, and time zone setting.
• Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content.
• Profile Data: includes your username and password, posts, body, message data, in-App purchase history, your interests, preferences, feedback and survey responses.
• Usage Data: includes details of your use of any of our Apps including, but not limited to, waves, messaging, reported posts, traffic data and other communication data, and the resources that you access.
• Log Information details of your use of the App.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your current location disclosed by GPS technology.
• Special Category Data includes information about your health, diagnosis, current status, but it may include other data such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions.
• Message Data includes the contents of messages you send and receive on the App and other usage of those services including logs.