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PRIVACY POLICY

This privacy policy is provided by Collctiv Limited, a company registered in
England with company number 11783005, whose registered address is Colony 5
Piccadilly Place Manchester M1 3BR ("we" or "us").  

As part of our business, particularly providing our Collctiv app (the “App”), we
collect basic personal details about users of the App, including group
organisers who download the App, and group contributors, who pay money into a
pot on the App (we refer collectively to such individuals in this policy as
“you” or “your”).  

Under UK data protection law, we have certain legal responsibilities about how
we collect, use, protect and share your personal information. If you have any
questions about how we use your personal information or any other questions
about this privacy policy, feel free to contact us, using the details set out in
paragraph 10 below.  

This policy explains our privacy practices in relation to how the App is used,
and covers the following:

 * Who this privacy policy applies to
 * What personal information is collected and used on the App
 * Sources of personal information
 * How we use your personal information
 * Parties who we share your personal information with
 * How long we retain your personal information for
 * Where your personal information is stored
 * How we legally justify using your personal information
 * Your legal rights in relation to your personal information
 * Other relevant information, including how to contact us‍

1. Who this privacy policy applies to

This privacy policy only relates to details that we collect and use, about
people who register for and use our App (“Organisers”) and also to people who
pay money to the Organiser, in relation to the App (“Contributors”) and also to
people who enter our competitions and giveaways. We also have a separate privacy
policy, which applies for visitors to our website.

‍‍‍

2. What personal information is collected and used on the App

‍‍

2.1 Information that we collect

 * Registration - The personal information that we collect from Organisers when
   they initially register to use the App will only consist of the following:
   their name, email address, password and date of birth.  
 * Contributors – we receive the name and email address of a Contributor, when
   they make a payment onto the App via the weblink.
 * Support - If an Organiser contacts us with a support query, we may collect
   further limited information about them, for instance, their telephone number.
    
 * Payments - When an Organiser or Contributor make payments on the App or via
   the weblink to the app, we also see summaries of the transactions, once they
   have taken place – for instance, we will see that you have paid £10 into a
   central pot, and that the Organiser has withdrawn a total of £100 into a
   separate bank account (and we will see whose name that separate account is in
   e.g. the Organiser’s personal account or an account set up in the name of the
   group itself).
 * Competitions and Giveaways - When you enter one of our competitions or
   giveaways we will process the information that is required to enter the
   competition or giveaway. This may include your name, email address, phone
   number, address or date of birth.

We will also see partial details concerning an Organiser’s and Contributor’s
payment card and/or bank account but at an anonymised level (we can only see the
last 4 digits) – so we will never have access to your full card details or bank
account details, nor will we be able to identify you from that incomplete card
number.

‍‍

2.2 Information collected and used by our third party service providers

If you are an Organiser for a group on the App, and you wish to make a
withdrawal from the central pot on the App, into a separate bank account, our
third party service provider may need to obtain further ID from you, as part of
anti-money laundering checks. This will usually entail asking for your name,
photograph on an official document which confirms your identity (e.g. a
passport) and your residential address and date of birth.

We do not currently collect, nor can we access any of the following types of
personal information which are likely to be used as part of the services
delivered through the App:

 * your bank account details (which are only available to the third party
   payment services provider who are responsible for delivering the App payment
   services (Stripe Payments Europe Ltd trading as Stripe, and Butlr Ltd trading
   as Ryft Pay)).  

The above service providers may therefore also collect personal data about you
separately from us when you use the App services. You can find out more
information about what personal data the service providers collect about you and
what they use it for, and how they protect it, via the following links:

 * Stripe (who provide the payment processing services and also carry out ID
   verification checks for us): https://stripe.com/gb/privacy
 * Ryft Pay (who provide the payment processing services and also carry out ID
   verification checks for us): https://ryftpay.com/privacy-policy
 * Google Cloud Platform (hosting of the App):
   https://cloud.google.com/security/privacy/

However, if you have any queries about how your personal information is being
used on the App, including by any of the above third party providers, please
contact us in the first instance, using the details set out at paragraph 10
below – we may then refer you to the relevant third party provider, depending on
the nature of your query.

‍‍

3. Sources of personal information

Generally speaking, we only collect and use your personal information that you
provide directly to us, whether this is when you register with the App, and/or
when you make transactions using the App or contact us with a support query. We
do not collect personal data about you from any third parties, except as
follows:

 * If you use the App in an unauthorised manner, another Organiser or
   Contributor may pass information to us;
 * If you enter a competition or giveaway that we are running jointly with
   another party and you enter the competition or giveaway through that other
   party who then pass your details to us;
 * If you pay money into the App using Apple pay or Google pay then we will
   receive your name and email address from those third parties; and
 * We may also receive information about Organisers from Stripe and/or Ryft Pay
   regarding anti-money laundering checks.

‍‍

4. How we use your personal information

We use your personal information in the following ways:

4.1 Organisers‍

Name, email and password - Registering an Organiser as a user and managing their
account e.g. handling support queries.

‍Date of birth - Verifying that an Organiser is old enough to use the App (it is
only available to users who are aged 18 and over).

Transaction details and partial card number - Storing for audit purposes and
ensuring that the App is used in a lawful and legitimate manner, in accordance
with our App user terms.

Name and email - We may also, from time to time, alert Organisers about new
features of the App and similar services, by email – however, you have the right
to opt out of this marketing at any time by contacting us at hello@collctiv.com
or clicking “unsubscribe” on any marketing message.

ID verification information - For anti-money laundering checks on Organisers.

‍‍

4.2 Contributors

‍Name, email - Recording payments on the App, including for audit purposes.‍

Transaction details and partial card number- Storing for audit purposes and
ensuring that the App is used in a lawful and legitimate manner.

‍

4.3 Competitions and Giveaways

Name, email, phone number, address - To process your entry to a competition or
giveaway and to notify you if you should win the competition or giveaway.

Date of birth - To verify that you meet the age requirements of our competition
or giveaway (if applicable).

‍‍

5. Parties who we share your personal information with

We only share your personal information with the following parties, who are our
third party service providers:

 * Stripe Payments Europe Limited trading as Stripe – who are our payment
   services provider and provider of identity verification for anti-money
   laundering compliance; and
 * Butlr Ltd trading as Ryft Pay - who are our payment services provider and
   provider of identity verification for anti-money laundering compliance; and
 * Google Cloud Platform – who host the App.

‍‍

6. How long we retain your personal information for

Organisers - For information on anti-money laundering checks, we need to be able
to access this information for 5 years, so we retain it for this period. We
retain all other personal information which we collect about you for as long as
you have an App account with us, plus 7 years.  

Contributors – we retain information about Contributors in personally
identifiable form for a period of 7 years after you have made a payment onto the
App, for financial auditing purposes (following which we fully anonymise the
information).

‍

7. Where your personal information is stored

We will not transfer any of your personal information outside of the United
Kingdom – it will be hosted on Google’s servers in London. However, please also
refer to the privacy policies of the relevant third party providers, available
via the links at paragraph 2 above. For instance, Stripe may transfer personal
data to the United States and other countries outside of the United Kingdom.

‍

8. How we legally justify using your personal information.

Every use that we make of your personal information must meet a lawful basis,
set out under data protection law. For the uses set out in this policy, the
lawful bases that we rely on are as follows:




8.1 Organisers

 * Name, password and email – managing your account, providing support services.

Legitimate interests - for the purposes of performing our contract with you, we
need to receive and use your personal information in order to register your
account and for you to use the App and receive support from us from time to time
– therefore, if you do not wish to share such personal information with us, you
will not be able to use our App and/or receive support services from us.‍

 * Date of birth – verifying your age.

‍Legitimate interests – specifically to be able to determine that you are old
enough to use the App.

 * Transaction details and part of your card number – audit purposes, managing
   use of our app.

Legal obligations – specifically for audit purposes as required under the
Companies Act 2006 and required by anti-money laundering laws; Legitimate
interest – specifically for other uses of transaction data – which is about
ensuring that our App is used lawfully and in accordance with our terms of use.

 * Name and email - marketing.

Legitimate interests – particularly, the need to promote new features of the app
and similar products and services which we introduce to existing users of the
App.

 * Name, ID documents and date of birth – for anti-money laundering checks.

Legal obligations - required by anti-money laundering laws.

‍

8.2 Contributors

 * ‍Name, email address, transaction details and part of your card number –
   audit purposes and recording transactions on the App.

Legitimate interests - for the purposes of performing our contract with you, we
need to receive and use your personal information in to provide support from us
from time to time – therefore, if you do not wish to share such personal
information with us, you will not be able to make a payment into our App and/or
receive support services from us; Legal obligations - specifically for audit
purposes as required under the Companies Act 2006 and required by anti-money
laundering laws; Legitimate interest - specifically for other uses of
transaction data – which is about ensuring that our App is used lawfully.

 * Name and email - marketing

Legitimate interests – particularly, the need to promote new features of the app
and similar products and services which we introduce to existing users of the
App.

‍‍

9. Your legal rights in relation to your personal information

If you have any questions in relation to our use of your personal information,
you should first contact us, using the contact details in paragraph 10 below.
Under certain conditions, you may have the right to:

 1. require us to provide you with further details on the use we make of your
    personal information;
 2. require us to provide you with an electronic copy of personal information
    that you have provided to us;
 3. require us to update any inaccuracies in the personal information we hold;
 4. require us to transfer a copy of your personal information to another data
    controller, in a structured, machine readable and commonly used format;
 5. require us to delete any personal information that we no longer have a
    lawful ground to use;
 6. require us to restrict our use of your personal information;
 7. if we use your personal information for direct marketing purposes, object to
    receiving any further direct marketing from us at any time;
 8. complain to the Information Commissioner at any time; and
 9. object to our uses of your personal information which are based on the
    'legitimate interests' legal ground. If any of our uses of your personal
    information based only on this legal ground is causing you undue harm, then
    we must cease using your personal information for that purpose.

Your exercise of these rights is subject to certain conditions and exemptions,
for example to safeguard the public interest in investigating crimes, or
protecting legal privilege. If you exercise any of these rights, we will check
your entitlement and respond in most cases within a month. As mentioned above,
it may be that we will need to refer you to one of our third party providers,
for instance if it relates to personal information concerning the card payment
feature or other third party service.

If you are not satisfied with our use of your personal information or our
response to you, you can complain to us, using the details set out at paragraph
10 below.

‍

10. Other information, including how to contact us

We will use reasonable endeavours to ensure that your personal information is
accurate. In order to assist us with this, you should notify us of any changes
to your personal information, by contacting us, using the email address below.

From time to time, we may make changes to our App and services and,
consequently, our privacy policy may change at any time in the future. We
therefore encourage you to review it from time to time, to stay informed of how
we are using your personal information.  

We are required to employ adequate technical and organisational security
measures to protect your personal information from any loss, destruction, damage
or unlawful disclosure. However, no transmission of personal information over
the internet or via the App can ever be guaranteed as secure. Consequently,
please note that we cannot guarantee the security of any personal information
which you transfer to us or which we transfer to you or a third party over the
App.

If you would like further information about the matters set out in this policy,
please contact us at: hello@collctiv.com


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© 2023 Collctiv Ltd. All rights reserved. Collctiv is a company registered in
England and Wales (Company number: 11783005)
Collctiv Ltd, Colony, 5 Piccadilly Place, Manchester, England, M1 3BR. VAT
number: 348654172