We are committed to protecting your privacy, and we take our responsibilities regarding the security of your information very seriously. This policy explains how we use your information and how we protect your privacy.
Please read this policy carefully, as we will ask you to give your express agreement to the terms of it (for example, by ticking a box).
1.1 In this policy, “we”, “us” and “our” refers to Mood Group Limited of International House, 24 Holborn Viaduct, London, United Kingdom, EC1A 2BN.
1.2 You can contact us:
(a) by post, to the postal address given above;
(b) by email, using the email address published on our website at https://mood.tech/ from time to time.
2.1 We may update this policy from time to time by publishing a new version on our website, or on our application.
2.2 We may notify you of any significant changes to this policy by email or using any other contact details we hold for you.
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 The following uses of your data may be uses by us, or the people or organisations which we are permitted by this policy to disclose your data to, including those businesses which you gave feedback on.
3.3 We may process your personal data that are provided in the course of you accessing our application, or in any other manner connected to you providing feedback (“personal data”). The personal data may include your voice, name, email address or other contact details. The personal data may be processed for the purposes of providing goods and/or services to you (by us or other parties) or our customers, maintaining back-ups of our databases and communicating with you. The legal basis for this processing will be consent.
3.4 We may process data about your use of our application and any related services (“usage data”). The usage data may include the IP address of your device, geographical location (this could apply if you choose an option to authenticate the location of the feedback you gave by activating an “allow once” GPS/location setting on your device, or by taking a photo and sending it to us, which will include a GPS tag), browser type and version, operating system, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of our application or services and creating products and/or services to be used by third parties.
3.5 Your data may be processed for the purposes of us, or third parties, offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing will be consent.
3.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.7 We may process any of your personal data identified in this policy, for the following reasons, which provide the legal basis for the processing:
(a) where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice – the legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks;
(b) the proper administration of our technology and business, and/or the performance of a contract between you and us and/or our customers.
3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) and to the businesses or companies who you gave feedback on, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 Your personal data may be transferred to and stored on third party servers.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data whilst we have a contract with you – including the contract created by this policy (and for six years thereafter to meet any possible legal requirements); and indefinitely for the purposes of marketing (unless you later let us know that you do not want us to retain your data for this reason).
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on how long we consider it is reasonable to retain such data for the purposes specified in Section 3.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included. Please seek legal advice, should you wish to know more.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure.
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, or for other legal reasons.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
6.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.12 You may exercise any of your rights in relation to your personal data by notice to us – see Section 1. 7. How to contact the appropriate authority 7.1 Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office who enforces data protection laws – https://ico.org.uk/.