Privacy Policy
The protection of our users' private data is a serious concern for us and you can feel safe when using the SKOLL service. The applications of our service include, in particular the purchase of Drink Gifts and recommend a venue. Our platform is accessible to you electronically via different end devices and in different ways, in particular via our web sites and apps. In the following, we refer to our entire offer, which appears under the brand name SKOLL, including all applications collectively as "service" or "services", irrespective of the way in which it is made accessible to you and the terminal device via which you access it. Where a provision relates only to a particular part of the service or a particular way of using or accessing it, this will be expressly stated, e.g. "web site" or "app".
Your privacy is a primary objective for us when processing personal data, which we always take into account. Personal data collected when using our services is processed by us in accordance with the statutory provisions of the UK's Data Protection Act (DPA) and the EU's General Data Protection Regulation (GDPR).
In the following, we inform you about the collection and processing of personal data during the general use of our services (irrespective of the actual use of our services) as well as during the use of our services and, if applicable, beyond that. At the end of this privacy policy, you will also find some general information - for example, on your data subject rights or general additions to previously listed processing, such as the storage period.
Data Controller
Person responsible for data processing is:
MYRMIDON LTD
6th Floor Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ
Web: www.skoll-app.com
Email: support@skoll-app.com
Phone: +44 (0) 7886 456 923.
(“SKOLL“, “we“, “us“, and “our“)
Definitions
The privacy policy of SKOLL is based on the terms used by UK's Data Protection Act (DPA) and the EU's General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used first.
We use the following terms, among others, in this privacy policy:
(a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by SKOLL.
(c) Processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling
Profiling shall mean any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller or data controller
SKOLL or person responsible for processing is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
(h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of SKOLL.
(i) Recipient
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task shall not be considered as recipients.
j) Third party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the users authorised to process the personal data under the direct responsibility of the controller or the processor.
k) Consent
Consent shall mean any freely given specific and informed indication of the data subject's wishes, in the form of a statement or other unambiguous affirmative act, by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.
Information on data subject rights
You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on each right on the Information Commissioners (ICO) website and you can simply follow the links provided to learn more.
· The right to restrict processing
· The right to data portability
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website.
Please direct all requests for information, requests for information or objections to data processing to us.
What are the relevant legal bases for processing your data?
The following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:
Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
Contract – This is where we process your information to fulfil a contractual arrangement, we have made with you.
Answering your enquiries – This is where we process your information to reply to your messages, e-mails, posts, calls, etc.
Legitimate Interests - This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
General data collection when using our services
When you use our services, whether purely for informational purposes or in connection with the active use of our services, we collect the personal data that your browser transmits to our server. Each time services are accessed, information is sent by the respective internet browser of your device to the server of our service and temporarily stored in log files, the so-called log files. The data records stored in this process contain the data, which are stored until they are automatically deleted:
The legal basis for the processing of the IP address is our legitimate interest results from:
- ensuring a smooth connection setup,
- ensuring a comfortable use of our services,
- evaluation of system security and stability.
A direct conclusion to your identity is not possible on the basis of the information and will also not be drawn by us. The information is stored and automatically deleted after the aforementioned purposes have been achieved. The standard periods for deletion are based on the criterion of necessity and are generally deleted after 24 hours.
Cookies
In order to make our services as pleasant as possible for you, we use cookies. Cookies are small text files that enable the user to be recognised so that you do not have to identify yourself each time. Cookies can also help us to tailor our offers to your interests. We use session cookies and permanent cookies on our web sites. We use these cookies to analyse the use of our offers and to provide you with interesting information. In principle, you can also use our web sites without cookies. To do this, you must set your Internet browser so that cookies are always rejected; however, the full range of functions of our services cannot then be guaranteed. For further information on cookies, please refer to our Cookie Policy.
Google Analytics
We use Google Analytics, a web analytics service provided by Google Inc, (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; "Google"). The use includes the Universal Analytics mode of operation. This makes it possible to assign data, sessions and interactions across several devices to a pseudonymous user ID and thus to analyse the activities of a user across devices.
Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymisation is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. Our legitimate interest in data processing also lies in these purposes. The legal basis for the use of Google Analytics is thus our legitimate interest. Sessions and campaigns are terminated after a certain period of time. By default, sessions are terminated after 30 minutes without activity and campaigns after six months. The time limit for campaigns can be a maximum of two years.
Advertising networks
We use cookies for marketing purposes to target our users with interest-based advertising. For this purpose, we also use cookies and tracking pixels from our cooperation partners, such as ad networks. The legal basis for this is our legitimate interest. In doing so, we may place a unique cookie and/or tracking pixel on your browser for the user advertised in the respective advertisement or read out such a cookie there. When the advertisement is placed, information about your visit to SKOLL, e.g. how often you viewed an advertisement, is collected and passed on to the advertising partner. A link with your user profile you have set up with us does not take place. In addition, no data, such as your name or address, is generated or passed on via advertising networks.
Re-targeting, re-marketing
In addition to the services and technologies mentioned above, our web site uses so-called re-targeting and re-marketing technologies, e.g. with our partners Google or Facebook. We use these technologies to make our website even more interesting for you. This technology makes it possible to target Internet users who have already viewed our web site with advertising on partner websites. We are convinced that the display of personalised, interest-related advertising is generally more interesting for the Internet user than advertising that has no such personal reference. The display of these advertisements on the pages of our partners is based on cookie technology and an analysis of previous user behaviour. This form of advertising is completely anonymous. No personal data is stored and no usage profiles are merged with your personal data.
Google Re-marketing
This function is used to present interest-based advertisements to website visitors as part of the Google advertising network. The browser of the website visitor stores so-called "cookies", text files which are stored on your computer and which make it possible to recognise the visitor when he/she visits websites that belong to the Google advertising network. On these pages, the visitor can then be presented with advertisements that relate to content that the visitor has previously accessed on websites that use Google's re-marketing function. It should be noted that we have no knowledge of the content of the transmitted data or its use by Google. According to its own information, Google does not collect any personal data during this process. However, if you do not wish to use Google's re-marketing function, you can deactivate it by making the appropriate settings at http://www.google.com/settings/ads or http://www.google.com/settings/u/0/ads/anonymous.
Alternatively, you can deactivate the use of cookies for interest-based advertising via the advertising network initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.aspError! Hyperlink reference not valid.here.
When using Google Re-marketing, the following data is processed: IP address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. The placement of interest-based advertisements using Google Re-marketing is based on a legitimate interest. The data collected for Google Re marketing purposes will be deleted or anonymised after 9 or 18 months.
Facebook Re-marketing
Our web sites may use retargeting functions (Custom Audiences) from Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. By means of this function, we can target visitors to the web site with advertising by displaying personalised, interest-related Facebook ads to visitors to the web site when they visit the Facebook social network. To carry out the function, the re-marketing tag of Facebook is implemented on the web site. Via these tags, a direct connection to the Facebook servers is established when visiting the web site. This transmits to the Facebook server which of our web pages you have visited. Facebook assigns this information to your personal Facebook user account. We would like to point out that we have no knowledge of the content of the transmitted data or its use by Facebook.
Facebook offers its users an opt-out for the display of advertisements that have been placed on the basis of re-marketing of website visits. For more information, please see Facebook's Privacy Policy . If you do not wish to have data collected via Custom Audiences, you can deactivate Custom Audiences in your Facebook profile or at www.youronlinechoices.com
When using Facebook Re-marketing, the following data is processed: IP address, date and device information. The placement of interest-based advertising via Facebook Re-marketing is based on our legitimate interest. The data collected in connection with the use of Facebook Re-marketing will be deleted or anonymised after 90 days at the latest or following the deletion or blocking of the profile.
Registration
You have the option of registering for our services on our web site and creating a user account. For the registration, we collect and store this data, which are processed for the execution of the SKOLL services and remain stored until revoked by the user or the expiry of legal retention periods.
You may also voluntarily provide additional details (personality information, preferences, and your interests, details about your education and training, hobbies, work experience, professional courses, etc.). Please note that you have choices about the information on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be available.
The legal basis for the processing of your personal data is the establishment and implementation of the user contract for the use of the SKOLL service. We store the data until you delete your SKOLL user account. Insofar as statutory retention periods are to be observed, data is also stored beyond the time of deletion of a user account.
Passwords
You should never disclose your password for accessing our portal to any third party and you should change it regularly. If you want to leave your account, you should press the logout and close your browser to prevent anyone from gaining unauthorised access to it.
Contacting Us
If you contact us the data you provide will be stored so that your message can be forwarded to the correct contact person. This is done in accordance with our legitimate interest to process your request. Your data provided will not be used for any other purposes, in particular not for advertising.
The use of our online services
The main purpose of our service is to buy and send Drink Gifts to your contacts. To do this, it is essential that you provide us with certain information and that we transmit data about you and information about you to third parties.
What data does SKOLL store?
When you register for and use our online services, we only collect the data that you provide to us. When you log in to our services, we also save the e-mail address used when logging in as well as the IP address you had at that moment. When our members use the service, we store the date of the visit and which parts of the service were used. In order to increase the interactivity of our offer, the visits of other profile pages, the collection status of messages or similar information are stored and also made accessible to the respective other participants in the service.
For what purposes does SKOLL process my data?
To the extent necessary, we also process your data in order to be able to provide our online services in accordance with the contractual relationship that exists with you.
Unsolicited Information
If you provide us with personal information that we have not requested then we will endeavour to only retain the information that we are otherwise entitled to hold because of the services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.
On what legal basis is my data processed?
We process the data provided and/or collected by you when using our services on the basis of the contractual relationship with you.
How long does SKOLL store the data?
We only store data and information to the extent permitted by law. As a rule, data is stored for the duration of the use of our services. Any storage beyond this is only carried out within the framework of existing statutory retention periods or periods of limitation.
Newsletter
You will receive newsletters from us at regular intervals with information and news about our services and your personal network. If you no longer wish to receive a particular newsletter, you can object to the use of your e-mail address for this purpose at any time. You will find a link to this effect in every newsletter. If you no longer wish to receive any newsletters at all, you can either unsubscribe from all variants of the newsletters yourself within the service or object to the use of your email address altogether.
Protection and transmission of your data
We will not share your email address with any third party at any time, unless we are required to do so by law or it is necessary for billing purposes or to make a claim.
Transfer of data
We do not share your personal information with third parties for purposes other than those described in this privacy policy.
We will only share your personal information with third parties if:
- you have given your express consent to this,
- the disclosure is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
- in the event that there is a legal obligation for the disclosure, as well as
- this is legally permissible and necessary for the processing of contractual relationships with you.
Administration, financial accounting, office organisation, contact management
We process data within the scope of administrative tasks as well as organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.
Business analyses and market research
In order to run our business economically and to be able to recognise market trends, wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of our legitimate interest, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimise our offer and to improve business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they are deleted or anonymised when the user terminates the contract, otherwise after two years from the conclusion of the contract. In all other respects, the overall business analyses and general trend analyses are prepared anonymously wherever possible.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the legal requirements.
Data deletion and storage period
In accordance with the deletion and storage periods specified in this privacy policy, your personal data will generally be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
Exceptionally, deletion does not take place immediately if
- we need the data for billing purposes or the assertion of claims
- there are factual indications that the service is being or has been used with the intention of not paying in full the fee that may be due,
- there are actual indications that the service is being or has been used in breach of contract or the law,
- we are obliged to store the data, e.g. in order to comply with statutory retention obligations.
Data security
We take appropriate technical and organisational measures, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Secure transmission of your data
In order to protect the data stored with us in the best possible way against accidental or intentional manipulation, loss, destruction or access by unauthorised persons, we use appropriate technical and organisational security measures. The security levels are continuously reviewed in cooperation with security experts and adapted to new security standards.
The exchange of data to and from our website is always encrypted. We offer HTTPS as the transmission protocol, in each case using the current encryption protocols.
Online Payment, Secure data transmission and Credit card information
The transmission of your personal information during an order transaction is encrypted using industry standard Secure Socket Layer ("SSL") technology, (SSL encryption version 3). Any credit card information you provide will not be stored by us, but will be encrypted and collected directly from our payment service provider via hypertext transfer protocol secure ("https").
We may share information with our payment service provider, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to our payment service provider’s own Privacy Notice and Terms and Conditions.
Social Media
We maintain online presences in social networks and platforms on the basis of our legitimate interests and in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Within our online offer, functions and widgets of social networks and platforms are integrated. When you click on or use any of those functions and widgets, your browser establishes a direct connection to the relevant social networks and platforms. The function or widget then transmits log data to the relevant social networks and platforms. This log data may contain your IP address, the address of the visited websites, type and settings of the browser, date and time of the request, your usage of the relevant social networks and platforms, as well as cookies. Those may also include the display of our post, the link to our profile, the possibility to interact with the posts and functions, as well as to measure users reach (so-called conversion measurement).
Do Not Track
Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.
Do Not Sell My Personal Information
We do not sell information that directly identifies you, like your name, address, banking information, or phone records. In fact, we do not even share that type of information except with service providers who can use the information solely to provide a service on our behalf, when a consumer directs us to share the information. If applicable, you can choose whether you want this sharing or not. Remember, we don’t sell data that directly identifies you unless we have your explicit permission, no matter what choice you make. To make your choices, please contact us.
Integration Of Services And Contents Of Third Parties
We use within our online offer on the basis of our legitimate interests, content or services offered by third-party providers in order to integrate their content and services.
This always requires that the third-party providers of this content are aware of your IP address, since the content or service could not send to your browser without the IP address. The IP address is thus required for the display of this content and we endeavor to use providers that only use your IP address for the delivery of the content or services. However, Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
Obligation to provide personal data
The use of our services is based on a contractual relationship concluded with us upon registration. As part of the conclusion of the contract, it is necessary for you to provide us with certain information. This concerns your e-mail address, first name, last name, date of birth and title. Without providing this information, it is not possible for us to establish a user relationship with you - the use of our service is therefore not possible without providing this data.
Processing for legitimate interest
If the processing of personal data is carried out on the basis of a legitimate interest, the legitimate interest usually results from the purpose of the respective processing or the legitimate interest lies in the performance of our business activities.
Children Data
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.
Promotional Communications
You may opt out of receiving promotional emails or communications from us by following the instructions in those emails or text messages or by visiting the “Notifications” tab in the “Settings” menu on our platform. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to licensors, and all entries made within our online offer or web sites.
Accuracy
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
Final provisions
We reserve the right to update this privacy policy from time to time in order to take into account any changes in the legal situation or the expansion of the functional scope of the platform. If there are material changes to this Privacy Policy, we will notify you in a prominent manner within our Service or by sending a notice directly to you. We encourage you to periodically review this privacy policy to be informed of how we are protecting your personal information.
If you have any questions about this privacy policy or data protection in general, please contact us.