INTRODUCTION

This privacy policy (together with our end-user licence agreement as set out at [WEB ADDRESS OF EULA] (“EULA”) and any additional terms of use incorporated by reference into the EULA, together our “Terms of Use”) applies to your use of the MyLifeRaft mobile application software (“App”).

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.

WHO WE ARE

We are Kuradocs Limited, a company registered in England and Wales with company number 09015297 and registered office at Cowes Business Centre, 232 Newport Road, Northwood, United Kingdom, PO31 8PE.  We are the controller for the App and are responsible for your personal data.

You can contact us at info@myliferaft.com.

CHANGES TO THE PRIVACY POLICY

We keep our privacy policy under regular review.  This version was last updated on 07.03.24. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. 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.

THIRD PARTY LINKS

The App may, from time to time, contain links to and from the websites of third parties, including 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:

• your email address.
• [the type of mobile device you use], [a unique device identifier [(for example, your mobile device’s IMEI number, the MAC address of the mobile device’s wireless network interface)], [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION] (“Device Data”).
• details of your use of our App including, but not limited to the resources that you access (“Usage Data”).
• your preferences in receiving marketing from us and third parties and your communication preferences (“Marketing and Communications Data”).
• [your current location disclosed by [GPS technology OR [OTHER TECHNOLOGY]] (“Location Data”).

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 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 your email address and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App or by corresponding with us (for example, by email). It includes information you provide when you download and first use the App and if you report a problem with the App. 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 we will automatically collect personal data including Device and Usage Data.

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses “cookies”, which are text files placed on your device, to help analyze how users use the App. The information generated by the cookie about your use of the App (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google Analytics collects information such as how often users visit our App, what pages they visit when they do so, and what other sites they used prior to coming to our App. We use the information we get from Google Analytics only to improve our App. Google Analytics collects only the IP address assigned to you on the date you visit our App, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
Google uses this data to track and examine the use of our App, to prepare reports on its activities, and share them with other Google services. Google may use the data collected on our app to contextualize and personalize the ads of its own advertising network.

[Location Data. We also use [GPS technology OR [OTHER 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.]

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 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.

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 use Device and Usage Data to administer and protect our business and improve the App including troubleshooting, data analysis and system testing.  This use is necessary for our legitimate interests of analysing how the App is used and to develop our services and grow our business.

We will use your email address to enable you to participate in a prize draw with your consent.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with:

• service providers acting as processors who provide IT and system administration services.
• professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

We may also share your personal data with the third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

DATA SECURITY

All information you provide to us is stored on our secure servers.

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

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

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.

• 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.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues.