We collect, use and are responsible for certain personal data about you. When we do so we are subject to all legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; the Data Protection Act 2018 (and regulations made thereunder); and the Privacy and Electronic Communications Regulations 2003 as amended.
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our||We are Auderli Limited, a company registered in England and Wales. Our company registration number is 11818553 and our registered office is Stanford Gate, South Road, Brighton, BN1 6SB, United Kingdom. Our brand name is "Auderli".|
|Personal data||Any information relating to an identified or identifiable individual as defined in UK GDPR.|
We may collect, use, store and transfer different kinds of personal data about you as follows:
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.
We will collect and process the following data about you:
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:
See “Glossary Legal Basis” below to find out more about the types of lawful basis that we will rely on to process your personal data.
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 get your express opt-in consent before we share your personal data with any third party for marketing purposes.
|Purpose/activity||Type of data||Lawful basis for processing|
|To register you as a new user||Identity,
|To process purchases and deliver Services including managing payments and collecting money owed to us||Identity,
Marketing & Communications
|Your consent. Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you including notifying you of changes to Our App or any Services||Identity,
Marketing & Communications
Performance of a contract with you.
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services).
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|To enable you to participate in a prize draw, competition or complete a survey||Identity,
Marketing & Communications
Performance of a contract with you,
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
|To administer and protect our business and Our App including troubleshooting, data analysis and system testing||Identity,
|Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content and advertisements to you,
To make recommendations to you about goods or services which may interest you,
To measure and analyse the effectiveness of the advertising we serve you,
To monitor trends so we can improve Our App
Marketing & Communications
Necessary for our legitimate,
interests (to develop our products/Services and grow our business)
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above.
Within Our App you will be able to share your Estate Data with people you trust such as, for example, your spouse, friend, beneficiary or a trusted third party advisor such as your accountant or your lawyer. Please only share your Estate Data with people you trust and note that you do you do so entirely at your own risk, and we shall bear no liability for any harm, loss or damage resulting from such disclosure by you.
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:
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access 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 and take all reasonable steps 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.
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 Our App for a period of 2 years then we will treat the account as expired and your personal data may be deleted.
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:
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 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.
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access 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.
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with the Information Commissioner (www.ico.org.uk).
Our full details are:
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 business 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.
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.