More4Apps (we, us, our) complies with applicable privacy and data protection laws when dealing with personally identifiable information (PII). PII is information about an identifiable individual (a natural person).
This policy sets out how More4Apps will collect, use, disclose and PII that you provide to us when you access and use this website or otherwise deal with us.
We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 28 May 2018.
We collect your PII from:
If possible, we will collect PII from you directly.
We may collect the following types of PII from you:
4.1 PII that you provide directly to us, including when you:
4.3 If you receive emails from us such as our newsletter, we collect information about your interaction with such emails, including read rates, link clicks and the when you opened the emails
4.4 PII collected from third parties where you have authorised this or the PII is publicly available, such as through LinkedIn
We use your PII provided directly by you:
We use information generated by your use of our website, products or services:
If you receive emails from us such as our newsletter, we collect information about your interaction with such emails, including read rates, link clicks and the when you opened the emails to analyse your engagement with our emails.
We may also use your PII:
We do not use your PII to make any automated decisions or to profile you.
We may disclose your PII to:
We may disclose research and statistical analysis on an anonymised basis derived from your PII to third parties.
We may also disclose PII we hold about you if we believe that such disclosure is necessary to:
A business that supports our website or our products and services may be located outside the European Economic Area (EEA). This may mean your PII is held and processed outside the EEA. Please see the GDPR Addendum for further information about personal data transfers from the EEA.
We will take reasonable steps to keep your PII safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing PII. More4Apps ICT devices, storage and channels and subject to continuous monitoring, logging analysis and audits. We regularly review and update our security systems to maintain the integrity of our security posture.
You can play an important role in keeping your PII secure by maintaining the confidentiality of any password used in relation to our products and services. Please do not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
Subject to certain grounds for refusal set out in applicable law, you may have the right to access your readily retrievable PII that we hold and to request a correction to your PII. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the PII relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the PII, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the PII that you requested the correction.
If you want to exercise either of the above rights, email our Privacy Officer at email@example.com. Your email should provide evidence of who you are and set out the details of your request e.g. the PII or the correction, that you are requesting.
While we take reasonable steps to maintain secure internet connections, if you provide us with PII over the internet, the provision of that information is at your own risk.
For the purposes of the GDPR we are the data controller (as defined in the GDPR) when processing personal data collected by us when you use our website or our services.
This GDPR Addendum was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal data. However, we are happy to provide any additional information or explanation needed. Any requests for further information should be emailed to our Privacy Officer at firstname.lastname@example.org.
The legal basis for our processing of information you provide directly to us or that is automatically collected when you use our website or our services is your consent, or that this information is necessary for the processing of a contract that we have with you, or that the processing is necessary for the purposes of our legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).
Despite the above, we may process any of your personal data where such processing is necessary for compliance with applicable laws.
Your rights in relation to your personal data under the GDPR include:
Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please email our Privacy Officer at email@example.com. If you are not satisfied by the way your query is dealt with by our privacy officer, you may refer your query to your local data protection supervisory authority.
We do not intend to collect personal data from children aged under 16. If you have reason to believe that a child under the age of 16 has provided personal data to us through our website and/or by using our services, please email our Privacy Officer at firstname.lastname@example.org.
The personal data we collect through this website or our other dealings with you may be transferred to, and stored in, a country operating outside the European Economic Area (EEA). Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.
We may transfer EU individual’s personal data from the EU to More4Apps’ entities in New Zealand, Australia or the USA.
The More4Apps group consists of the following companies:
New Zealand is recognised by the European Commission as a country that ensures an adequate level of data protection and we rely on this decision when transferring personal data from the UK to New Zealand.
More4Apps INC have entered into Standard Contractual Clauses as published by the European Commission. The Standard Contractual Clauses provide specific guarantees around transfers of personal data.
Third party processors
The personal data we collect may also be processed by the third parties set out below.
For personal data processed in the United Sates, the European Commission has determined that the United States ensures an adequate level of protection for personal data transferred from the EU to organisations in the United States under the EU-U.S. Privacy Shield. We have verified that our United States-based data processors have self-certified under the EU-US Privacy Shield framework.
For data held outside the EU or the United States, we have entered into Standard Contractual Clauses as published by the European Commission with our third party processors. The Standard Contractual Clauses provide specific guarantees around transfers of personal data and we rely on the Standard Contractual Clauses in transferring personal data to these third party processors.
List of third party processors as at 25 May 2018:
|Third party processor||Purpose||Location of processor||Policy pages|
|Pardot||Customer relationship management||USA||https://www.salesforce.com/company/privacy/|
|Salesforce||Customer relationship management||USA||https://www.salesforce.com/company/privacy/|
The personal data that we collect and process will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. We securely destroy personal data at the end of any data retention period.
The name and contact details for our European GDPR representative is as follows:
Name: Steve West, More4Apps UK Limited
Address: 3000 Cathedral Hill, Guildford, Surrey, GU27YB
Phone: +44 (0) 1483 243508