Welcome! This document sets out how we process personal data via our app and services. Please read this policy carefully – it is important. If you do not accept it, then we can not allow you to access the app or our services.

The app allows you to join a network of other users within a defined location (we call this a “Location”). When you are in that Location, and you use the App, your presence there will be known to all other users in that Location at that time.

If the Location is managed by an organisation, like your employer, or the operator of your accommodation, we call them an “Operator”. When you use the App at a Location, the relevant Operator will also know that you are in that Location.

You can do all sorts of things like chat to users, arrange to meet up, share content with all users or just the users you have connected with – it’s up to you. We ask that you think carefully about what information you share, how you use others’ information, and that you are always respectful. We have set out our “community rules” in our End User Terms here – these set out how we expect you to behave, when you use the app and our services.

If you have any questions regarding these terms or the use of our app, please feel free to contact us by emailing or calling our customer services team, whose contact details are provided below.

To comply with applicable data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.

Introduction

Ralutech Limited are committed to protecting your personal data and respecting your privacy.

This policy (together with our end-user terms as set out at https://console.theisland.app/terms-and-condition.html (End User Terms) and any additional terms of use incorporated by reference into the End User Terms, together our Terms of Use) applies to your use of:

• The Ralutech mobile application software whether that’s via your mobile device or your computer (App) and any updates or supplements to it.

• Any of the services accessible through the App (Services) unless the End User Terms state that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.

• If you contact us about the App or our Services.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, or that we receive from others about you in relation to the App and our Services, will be processed by us.

This App is not intended for children and we do not knowingly collect data relating to children under the age of 18. If you are under the age of 18, please do not submit any personal data through our App or via our Services. We encourage parents and legal guardians to monitor their children’s use of the internet and to help enforce our privacy policy by instructing their children not to share their personal data without permission. If you have reason to believe that a child under the age of 18 has provided personal data to us through our App or via our Services, please contact us, and we will use commercially reasonable endeavours to delete that data.

Please read this privacy policy carefully to understand our practices regarding your personal data and how we will treat it.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below:

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

11. DESCRIPTION OF CATEGORIES OF PERSONAL DATA

1. Important information and who we are

Ralutech Limited is the controller and is responsible for your personal data (collectively referred to as "Ralutech", "we", "us" or "our" in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Ralutech Limited

• Data Privacy Manager

• Email: hello@ralu.tech

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated in October 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email . The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App or the content shown on it may, from time to time, contain links to and from the websites of third party networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check the privacy policies before you submit any personal data to these websites or use these services.

2. The data we collect about you

Our mission is to facilitate meaningful in-real-life connections. To do that, we need to collect some personal data about you to provide the Services and allow users to connect with others within defined Locations. We collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.

• Contact Data.

• Location Data

• Service Data.

• Device Data.

• Content Data.

• Profile Data.

• Usage Data.

• Marketing and Communications Data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not ourselves collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we ourselves collect any information about criminal convictions and offences. However, the App allows users to share information which may contain this type of sensitive information, which we can not control.

If you have a concern about any data that is processed via the App, please contact us.

3. How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity Data, Contact Data, Service Data, Profile Data and Marketing and Communications Data) you give us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download an App, subscribe to any of our Services,  use the App, share data via an App's chat functions, or social media functions, enter a competition, promotion or survey and when you report a problem with an App, or our Services. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device. Each time you use our App we will automatically collect personal data including Location Data, Device Data, Content Data and Usage Data.

• Location Data. If you use our App and wish to use the Services, you will be asked to consent to your Location Data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings, deleting the App. See further details about how Location Data is used below

• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  • Authentication Services

    If you log into our Apps through a third party authentication service (such as via Facebook, LinkedIn, Google or Apple), otherwise provide us with access to information from their authentication services or authorise us to connect with a third party service, we will access Identity Data and Contact Data  from those third party authentication services, combine that with information we collect about you in other ways set out in this privacy policy, and use and disclose it as set out in this privacy policy. Any access that we may have to such information from a third party authentication service is in accordance with the authorisation procedures set out by that service. You should check your privacy settings on the third party services to understand and change the information sent to us through these services. For example, you may choose to log in to the App using single sign-in services such as Facebook Connect or an Open ID provider. These single sign-on services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities to your profile page to share with others within your network.

  • Other users

Other users of our App might provide information about you as they use the App or our Services. For example, we might collect information about you if another user contacts us about you, or posts content which relates to you via the App.

• Social Media Widgets which will allow you and others to share content via social media platforms outside of the App. If you do allow this, then that content (which may include your personal data) will be made available via those platforms and will be subject to the platforms’ own terms and privacy policies.

• Unique application numbers. When you want to install or uninstall an App containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

4. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose/activity: To install the App and register you as a new App user
Type of data: Identity, Contact, Device
Lawful basis for processing: Your contract

Purpose/activity: To log into the App via a third-party authentication service
Type of data: Identity
Lawful basis for processing: Your contract

Purpose/activity: To determine if you are in an active Location or not
Type of data: Location
Lawful basis for processing: Your contract

Purpose/activity: To add information to your personal profile
Type of data: Identity, Profile
Lawful basis for processing: Your consent

Purpose/activity: To select the correct hashtags in the island
Type of data: Profile
Lawful basis for processing: Your contract

Purpose/activity: To build a network of 'friends'  at the Location (i.e. say 'hi' to other users who are in the same Location)
Type of data: Profile
Lawful basis for processing: Your contract

Purpose/activity: To communicate with other users via the in-app chat
Type of data: Chat
Lawful basis for processing: Your contract

Purpose/activity: To record and publish a video story, which will be visible from other users in the Location
Type of data: Video recordings
Lawful basis for processing: Your consent

Purpose/activity: To upload your content to the App for other users in the Location
Type of data: Content
Lawful basis for processing: Your contract

Purpose/activity: To contact us for technical support (via the in-app contact form or otherwise)
Type of data: Service
Lawful basis for processing: Your contract

Purpose/activity: To determine what type of operating system the device is running (iOS or Android)
Type of data: Device
Lawful basis for processing: Your contract

Purpose/activity: To generate activity reports and usage dashboards, to make these available to the Operator at the Location you are in (if there is one).
Type of data: Usage
Lawful basis for processing: Our Legitimate interest and the Operator to manage the App efficiently

Purpose/activity: To manage our relationship with you including notifying you of changes to the App or any Services
Type of data: Identity, Contact, Profile, Marketing and Communications, Usage
Lawful basis for processing: Your consent, Performance of a contract with you, Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services), Necessary to comply with legal obligations (to inform you of any changes to our Terms of Use)

Purpose/activity: To enable you to participate in a prize draw, competition, promotion through the App or our Sites, or complete a survey
Type of data: Identity, Contact, Device, Profile, Marketing and Communications
Lawful basis for processing: Your consent, Performance of a contract with you, Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

Purpose/activity: To administer and protect our business, this App and our Services including troubleshooting, data analysis and system testing
Type of data: Identity, Contact, Device, Usage
Lawful basis for processing: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

Purpose/activity: To deliver content and advertisements to you, To make recommendations to you about goods or services which may interest you, To measure and analyse the effectiveness of the Services and advertising we serve you, To monitor trends so we can improve the App
Type of data: Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, Location
Lawful basis for processing: Consent, Necessary for our legitimate interests (to develop our products/Services and grow our business)

5. Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the list above:

• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Other App users - in order to help you interact with other users, we share your information with other users.

• The Operator of your Location (if there is one)

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We may also disclose personal data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected..

6. International transfers

We do not transfer your personal data outside the UK, although you may access it from outside the UK.

7. Data security

Where we have given you (or where you have chosen) a password or access code that enables you to access certain parts of the App or our sites, you are responsible for keeping this confidential. We ask you not to share a password or access code with anyone.

Ensure when using certain Services which include social networking, chat room or forum features, that you do not submit any personal data that you do not want to be seen, collected, used or shared by other users.

Once we have received your information, we use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. These include:

• Access to your account is controlled by use of a third-party authentication service that is unique to you.

• All information you provide to us is stored on our secure servers which are provided by an external cloud service provider based in the UK.

• Access by Ralutech personnel is strictly controlled.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so. If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting us.

8. Data retention

If you have been using the App, once you have stopped actively using it, there will be a window of 1 hour from your last interaction with the App (we call this the “Inactivity Window”). During that Inactivity Window:

• We will continue to display your presence within the Location to other users and the Operator (if there is one). That will only update if you open the App.

• Your video stories will remain visible as part of your profile. After the Inactivity Window, the video will no longer be available, and you will need to record a new video story if you want to.

Ralutech Ltd will store your data for as long as required for legitimate business purposes (as set out in section 4 above) and in order for you to use your account.

In the event that you do not use the App for a continuous period of two years then we will treat the account as expired and your personal data will be deleted.

In practice, we delete or anonymise your information upon deletion of your App account. Otherwise it is kept:

• For the length of an active App account;

• For as long as required to bring an outstanding issue, claim or dispute to closure or to process a report on fraudulent behaviour;

• For five years when the account is suspended or block due to actual or potential breach of the Terms of Use;

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfill the purposes outlined in this privacy policy or earlier in some circumstances where you can ask us to delete your data: see Your legal rights below for further information.

Please note that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints. In addition, even if we delete your data, it may persist on backup or archival media for legal, tax or regulatory purposes.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. These are set out in the policy below.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us.

10.   Glossary

Lawful basis:

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties:

Internal third parties

Other companies within our group of companies which may provide support services such as IT and system administration services and undertake leadership reporting.

External third parties

The Operator at your Location, if there is one, in particular where they use our dashboard.

Service providers which might include data hosting and maintenance, customer care, analytics, marketing, advertising, payment processing and security operations. Please note that all service provider must agree to strict confidentially obligations;

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors, controllers or joint controllers who require reporting of processing activities in certain circumstances.

We may also disclose data to third parties to enforce legal rights. For example, we may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing;

Your legal rights:

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data's accuracy;

  • where our use of the data is unlawful but you do not want us to erase it;

  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. Description of categories of personal data

• Identity Data: When you set up an account to use our App/ products/services, you provide us with your login credentials, which include your full name and profile picture, which we use to authenticate you. If you use a third party authentication account to logon, we receive your public information as provided by that service.

• Contact Data: email address.

• Location Data:

  • The App’s unique offering is to enable you to view and be visible to other users in pre-defined activated locations, with a view to connecting and interacting with those who are in the Location. When you login, you will be asked to deliberately authorise the collection and processing of your location data to allow the App to recognize your presence in the Location and to share this and your profile with other users in the same Location and the Operator, if there is any.

  • Your geo-location is automatically checked every time you launch or refresh the App to determine if you are inside an active location. If you are outside of the active Location the App will inform that the service is not available and your location data will not be shared with anyone.

  • The data collected therefore includes your current location disclosed by geolocation data (i.e.  your latitude and longitude data taken from your device, through the following technologies, depending on the service and type of device you are using: GPS data, Bluetooth or data about connection with local wifi equipment).

  • Our location-enabled Apps require this Location data for their features to work. The Location data are used for real-time processing but are not stored by us or anyone.

  • You are free to withdraw your consent at any time and disable your device’s geolocation settings. If you choose to do so, you will not be able to make yourself visible in the location or to see other people in the location around you.

  • The App does not share historical information on your location settings with other users.

• Service Data: includes information provided when you contact us via our in-app contact form.

• Device Data: includes

  • Operating system (iOS and Android)

• Chat Data: includes:

  • Messages you publish on the public channel (visible to all users who are 'in the Location') or when you communicate 1-1 with another user. We process your messages with other users of the App. This includes the content you publish and is part of the operation of the Services. 1-1 messages are strictly private and stored on the App’s servers to enable a conversation to happen between ‘friends’ on the App. These are not accessible to other users not involved in the conversation. Ralutech’s authorised managers do not view conversations between friends, except if requested for judicial reasons and /or in compliance with legislative or administrative reasons.

• Content Data: includes

  • Information stored within your account, including friends' lists (our App remembers which users you have previously  connected with in the App (think of your network of friends within the residence that you build via the App). Users invite manually other users to become "friends". This is a two-way process that requires one user inviting and the other user accepting the friendship.

  • Photos, videos or other digital content, check-ins. If you upload video stories in our Apps, those video stories remain visible to other users only for the period the uploader is "in the Location". When the user leaves the Location, his/her video stories are not visible to other users any longer plus the Inactivity Window explained above. However, stories are saved in our database.

• Profile Data: includes, in relation to our Apps:

  • Your age, gender and nationality, which you can choose to share. If you do choose to share this, it will be visible to other members as part of your profile.

  • Information about your interests, preferences - expressed via the in-app hashtags.  

  • Any feedback and survey responses received from you that we use for research purposes (although you are not obliged to respond to them), you may give us responses to our questions, insights into your opinions and insights into our products and Services.

  • Any further information that you choose to add to your profile which may include your profession, details on your personality, preferences, interests, lifestyle and content such as photos and videos. When you add photos and videos to your profile, you may allow us to access your photo album or camera. By choosing to provide this information, you consent to us processing that information.

• Usage Data: To monitor usage statistics for our Services we collect and process activity data such as last connection, date and time you logged in, features you used and the type and number of interactions with other users of the App (for example, friends, and the number of messages you send and receive), whether this is required for our own purposes or otherwise. We may share this with the Operator of your Location, if there is one;

• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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