Privacy & Cookies Policy – Ugly Mugs Ireland

1. Introduction

1.1 We are committed to safeguarding the privacy of our website and mobile app visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website and mobile app visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website and mobile apps. Insofar as those cookies are not strictly necessary for the provision of our website and mobile apps and services, we will ask you to consent to our use of cookies when you first visit our website or mobile apps.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive email newsletter communications. You can access the privacy controls via https://uglymugs.ie/members/profile/.

1.5 In this policy, "we", "us" and "our" refer to Safe IQ Ltd. For more information about us, see Section 15.

2. How we use your personal data

2.1 In this Section 2 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

2.2 We may process data about your use of our website and mobile apps and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website, mobile apps and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website, mobile apps and services.

2.3 We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website and mobile apps, providing our services, ensuring the security of our website, mobile apps and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.4 In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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, or in order to protect your vital interests or the vital interests of another natural person.

3. Providing your personal data to others

3.1 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. Retaining and deleting personal data

4.1 This Section 4 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.

4.2 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.

4.3 We will retain your personal data as follows:

(a) usage data will be retained for a minimum period of 2 years following your last visit to our website or mobile apps, and for a maximum period of 6 years following your last visit to our website or mobile apps; and

(b) account data will be retained for a minimum period of 2 years following your last visit to our website or mobile apps, and for a maximum period of 6 years following your last visit to our website or mobile apps.

4.4 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 the following criteria:

(a) the period of retention of other data will be determined based on our legal obligations and legitimate business interests.

4.5 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. Security of personal data

5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

5.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

5.3 The following personal data will be stored by us in encrypted form: your password(s).

5.4 Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

5.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

5.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website and mobile apps confidential and we will not ask you for your password (except when you log in to our website and mobile apps).

6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7. Your rights

7.1 In this Section 7, 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 in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(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.

7.3 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. You can access your personal data by visiting https://uglymugs.ie/members/profile/ when logged into our website.

7.4 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.

7.5 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. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

7.6 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; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7 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.

7.8 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.

7.9 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. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.10 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.

7.11 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.

8. Third party websites

8.1 Our website and mobile apps includes hyperlinks to, and details of, third party websites.

8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

9. Personal data of children

9.1 Our website, mobile apps and services are targeted at persons over the age of 18.

10. Updating information

10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

11. About website and mobile app cookies

11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

11.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

12. Website and mobile app cookies that we use

12.1 We use cookies for the following purposes:

(a) authentication - we use cookies to identify you when you visit our website and mobile apps and as you navigate our website and mobile apps (cookies used for this purpose are: PHPSESSID);

(b) status - we use cookies to help us to determine if you are logged into our website or mobile apps (cookies used for this purpose are: wordpress_test_cookie, wordpress_{hash}, wordpress_logged_in_{hash}, wp-settings-{hash}, wp-settings-time-{hash});

(c) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website, mobile apps and services generally (cookies used for this purpose are: wfwaf-authcookie-{hash} );

(d) translation - we use cookies to store language settings (cookies used for this purpose are: _icl_current_language, _icl_current_admin_language_{hash},_icl_visitor_lang_js, wpml_browser_redirect_test, wpml_referer_url, wpml_admin_referer_url) ; and

(e) support - we use cookies to manage your use of our support centre and tickets system (cookies used for this purpose are: _zendesk_shared_session, _zendesk_session, _help_center_session) .

13. Cookies used by our service providers

13.1 Our service providers use cookies and those cookies may be stored on your computer or phone when you visit our website or use our mobile apps.

13.2 We use Google Analytics to analyse the use of our website and mobile apps. This service uses cookies for gathering information about website and mobile app use by means of cookies. The information gathered relating to our website and mobile apps is used to create reports about the use of our website and mobile apps. You can view the privacy policy of this service provider at https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gid, _gat.

14. Managing cookies

14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

14.2 Blocking all cookies will have a negative impact upon the usability of many websites and mobile apps.

14.3 If you block cookies, you will not be able to use all the features on our website and mobile apps.

15. Logging of website and mobile app searches for phone numbers

15.1 We do not log website or mobile app searches for phone numbers.

16. Mobile apps

16.1 Our Apple mobile app requests access to your location while you are using the app. This is for the purposes of providing you with location relevant services such as "Nearby Alerts". We do not log this location information. In your phone settings you may disallow the Ugly Mugs app from having location access. If you do this, you can still get location relevant services such as "Nearby Alerts" by manually setting a location in the Ugly Mugs app.

16.2 Our Google mobile app requests access to your location while you are using the app. This is for the purposes of providing you with location relevant services such as "Nearby Alerts". We do not log this location information. In your phone settings you may disallow the Ugly Mugs app from having location access. If you do this, you can still get location relevant services such as "Nearby Alerts" by manually setting a location in the Ugly Mugs app.

16.3 Our Google app requests access to your incoming and outgoing call/SMS lists, contact list and SMS log and the 'Draw over over apps' permission. This is for the purposes of providing the automatic call and and SMS screening and pop up alerts feature of our Google app. The app sends the phone number of all incoming and outgoing calls and incoming SMS to us. Our systems then check if that phone number is listed in our database. We return the result of this query to the app, which then provides you with a pop up alert advising you of the result of that check. During this process we do not log your phone number or the phone number being checked against our database. In the Ugly Mugs app "Settings" section you can switch off call/SMS screening if you do not want to use this part of the service. You may also disallow the Ugly Mugs app access to your incoming and outgoing call/SMS lists and the the 'Draw over other apps' permission in your phone settings. If you do not allow the Ugly Mugs app access to incoming and outgoing call/SMS lists and the 'Draw over over apps' permission, then the app will not be able to provide you with pop up alerts.

17. Our details

17.1 This website and our mobile apps are owned and operated by Safe IQ Ltd.

17.2 We are registered in England and Wales under registration number 08640270, and our registered office is at Suite 234, 9 Jerdan Place, Fulham, London SW6 1BE.

17.3 You can contact us by using our website contact form.

18. Data protection registration

18.1 We are registered as a data controller with the UK Information Commissioner's Office.

18.2 Our data protection registration number is ZB289036.