This website/app is operated by SpottyEgg Ltd.. We take your privacy very seriously therefore we urge to read this policy very carefully because it contains important information about on:
Who we are
SpottyEgg Ltd. ('we' or 'us') (trading as iCantHear) collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including the United Kingdom) and we are responsible as 'controller' of that personal information for the purposes of those laws.
The personal information we collect and use
a) Personal information you provide to us
We collect the following personal information that you provide to us:
We do our best not to collect any information, we only use a cookie or localstorage to create a session. Neither personal information or the conversations are recorded.
b) Personal information from other source
We may receive information about you from other sources. This information includes:
We may obtain information from Facebook or other social networks with your permission.
We may obtain your rough location from IP-to-location services.
We will add this information to the information we hold about you for the following purposes:
Delivering you a better user experience, such as pre-selection the correct language.
c) Monitoring and recording communications
We may monitor communications such as emails and telephone calls for the following purposes:
Quality assurance, training, to prevent bullying, harassment and for compliance.
d) Cookies and similar technologies
A cookie is a small text file which is placed onto your computer or electronic device when you access our website/app. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website/app.
Usage patterns to improve user experience. We never send personal data to third parties. We use Google Analytics and Facebook tracking technologies.
This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.
In addition it should be noted that in some cases our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
How we use your personal information
We collect information about our users for the following purposes:
To identify you and manage any accounts you hold with us; process orders; conduct research, statistical analysis and behavioural analysis; carry out customer profiling and analyse your preferences.
Who your information may be shared with
We may share your information with:
Law enforcement agencies in connection with any investigation to help prevent unlawful activity
None at the moment, but we may have clients for our data. The information would always be anonymised.
We will not share you personal information with any other 3rd parties.
We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call.
We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.
Keeping your information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:
User account access is controlled by a magic link, so the vulnerability depends on your facebook or emails account security not ours;
all data is stored on secure servers (AWS in the US);
all data transfer to apps and browser are SSL encryted.
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.
Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.
Transfers of your information out of the EEA
We may need to transfer your personal data to the following countries outside of the European Economic Area:
These transfers will be undertaken for the purpose of
Personal information is sent to our database which is hosted in the USA;
Images uploaded by the user are stored and analysed in the USA;
Basically all of the data is hosted by AWS in the USA. We are considering moving to a EU datacenter by some of the AWS services we use are not available in the EU AWS datacenters yet.
Any transfers to these countries will be undertaken on the basis that that country, territory or one or more specific sectors in that country, or an international organisation ensures an adequate level of protection.
For more information on the basis of any non-EEA transfers, our safeguards or Commission details, please contact us as described below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Children and the validity of consent
Where we obtain consent from any user we will take reasonable steps to ascertain whether the user is over 13 years of age and whether the child is sufficiently informed to give valid consent. If the user is not, parental consent will be required to provide consent for the processing of any personal information.
What rights do you have?
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further informaiton on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)
If you would like to exercise any of these rights please:
From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
By email if you have opted in to receive emails.
If you have any questions about this policy or the information we hold about you, please contact us by:
e-mail: [email protected]
8-9 hoxton sq.