This policy was last updated on 10 February 2021.
WHO WE ARE
The controller is Bowimi Limited (referred to as “we”, “us” or “our”) and we are committed to complying with the UK’s data protection law and the EU General Data Protection Regulation (GDPR) for the protection of personal data, as well as the principles of data security in the configuration of our services. We can be contacted at our Registered office address:
1 Widcombe Crescent,
If you have any questions about this privacy notice or how we use your personal data, please email firstname.lastname@example.org
THE DATA WE COLLECT ABOUT YOU
In order for you to enjoy our services which may include using guest-wifi and receiving promotions we need to use the information you provide us during sign-up (such as age, gender and preference information) to provide information about promotions or distribute gifts on behalf of participating venues and brands, including:
(a) information contained in your user profile;
(b) details of your current visit to a venue and any previous use of our services; and
(c) confirmation of when you have entered, or are in the vicinity of, a particular venue.
We process and store data relating to the redemption of gifts under each Promotion and share such data as set out below in clause 4.3.
The types of personal information we collect may include:
Personal details – including your name, email address, phone number, age, gender information regarding your use of our services, device information and browser information;
Location data – we may collect device information (e.g. IP address) when accessing our services. We may use the location data to share available Promotions in venues that are near you.
Preferences – we may collect information about your purchase history/gifts redeemed, venues you have attended or enquired about and any feedback you may give or reviews you may submit;
Your interactions with us – for example if you send us information via email, survey, social media, customer service communications or other methods, this may be stored on our systems;
Technical information – when you use our services, our systems may automatically record information on its server logs from your browser, including the location, IP address, cookie information and details about the page you requested.
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.
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 details of promotions and other marketing communications if we have your consent. You have the right to withdraw that consent at any time by contacting us. If you opt out you will not be able to participate in Promotions or receive notice of any gifts. You may opt out of receiving these details at any time by visiting www.bowimi.com/optout.
We have set out in a table below a description of all the ways we plan to use your personal data and the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Whenever we process your personal data under the ‘legitimate interest’ lawful basis, we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Purposes for which we will use your personal data:
DISCLOSURES OF YOUR PERSONAL DATA
We share your personal information only with the people who need to handle it so we can provide our services to you. This includes:
Our staff engaged in providing you with our services.
Suppliers who provide us with products and services or support to our IT tools and systems.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. A list of our third-party service providers is available on request. When you consent to providing us with your personal data, we may also share your personal data with the third parties set out below:
The following external third parties:
Service providers based in the UK or EEA who provide IT and system administration services.
Professional advisers if any
We also share aggregated data with participating brands and venues relating to the take-up of each Promotion for them to understand its effectiveness. All data that we share is aggregated and anonymised and we will not share any personal data that identifies you as an individual with any of our participating brands or venues.
Whenever we transfer your personal data out of the European Economic Area (“EEA”), 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 certain parts of our systems, 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.
We may retain your personal data only for as long as we require it for the purposes for which it is processed (or as is otherwise required by applicable law). If you terminate your contract with us and stop using our services, we may continue to process your personal data for a reasonable period and as required under applicable law.
When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete or anonymise your personal data.
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
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.
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