Voisey Privacy Policy

Last updated: March 2021

This privacy and cookies policy ("Privacy Policy") explains how the personal data we collect from you ("you", "your", or "user"), or that you provide to us, will be processed by us.

Please read the following information carefully to understand what data we collect, how that data is used and the ways it can be shared by us and you.

The data controller of your personal data is Voisey Entertainment Limited, a company which owns and provides the Services, registered in England and Wales under company number 11515002 and with registered office address at:

The Broadgate Tower Third Floor, 20 Primrose Street, London, United Kingdom, EC2A 2RS

("Voisey", "we", "our", or "us")

We provide the Voisey mobile application software ("App") and the Voisey website which can be found at www.voisey.app ("Website") (together the "Services")

Table of Contents

1. What information is collected?

Information you give us

This is information about you that you give us by:

  • onboarding with the App;
  • filling in the "Contact Us" form on the Website;
  • completing our online surveys;
  • entering into transactions with us;
  • providing us with feedback about the Website or our Services; or
  • corresponding with us by phone, e-mail or otherwise.

This may include personal data such as your name, email address, postal address (including city, state, post or zip code), telephone number, date of birth, income level, and any payment details that you may provide us with.

Information we collect through the Services

Each time you use the Website or App, we automatically collect the following information:

  • content you create, which may include video and voice recording;
  • information contained in the messages you send through our App;
  • your contacts, if you give us permission to access the phone book on your mobile device;
  • technical information, including the Internet protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
  • information about your visit, including the dates and times you use the Website/App, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, your geographical location when accessing the Website and any phone number used to call the contact phone number provided on our Website.

Information provided by third parties

If you grant us permission to do so during the onboarding process, we may receive information from your third party social network providers, including your:

  • name;
  • profile picture;
  • email address; and
  • friends list.

Special categories of data

We do not 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) unless you specifically choose to make this information available through the Services.

2. How we use your personal data

We may use personal data held about you in the following ways:

Information you give to us

We will use this information:

  • to set up a user account for you;
  • to respond to any enquiry you should make;
  • to offer and improve the Services and other products to you;
  • to provide you with information about other products and services we offer, where you have opted to receive such information;
  • to fulfil any order you make with us;
  • to notify you about any changes to the Services;
  • to send you promotional correspondence from us, to enable you to participate in contests or receive special offers where you have provided us with your consent; and
  • to contact you, if necessary in connection with the Services. For example, this may be where we wish to verify your account, or where you have been reported for a violation of our Terms of Service.

We may also use information from Apple’s TrueDepth camera to improve the quality of Lenses. Information from the TrueDepth camera is used in real time—we don’t store this information on our servers or share it with third parties.

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 your relationship with us.

Information we collect about you and information provided to us by third parties

We will use this information:

  • to ensure that the Services operate effectively and for internal operations, including technical administration, troubleshooting, data analysis, crash analytics, testing, research, statistical and survey purposes;
  • to provide you with a better experience, to improve the quality, value, functionality and general user friendliness of the Services, and to analyse and understand how the Services are used as part of our efforts to keep the Services safe and secure;
  • to serve you with advertisements and other information appropriate to your interests, including making suggestions and recommendations to you about Services we and our carefully selected third parties may offer that may interest you, where you have opted to receive such information; and
  • to serve any aspect of the Services to you according to your preferences and/or location.

Most personal data is processed on the basis that it is necessary for us to do so for the performance of the Services in accordance with the EULA (contact details, content, transaction information etc).

Where any of the processing activities described in this privacy policy are not strictly necessary for the performance of the contract between us and you (the EULA), we will process your personal data 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. Legitimate interest to this extent means the interest of our organisation in conducting and managing our business to enable us to give the best possible service to our members and the best and most secure experience on our Website as well supporting our marketing or business development objectives. It also means dealing with correspondence and defending our business through establishing and enforcing our rights.

Where relying on legitimate interests as our legal basis for processing your personal data, 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 (or those of a third party). 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).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you and the use of non-essential cookies.

4. Is your personal data shared or disclosed?

Voisey is not in the business of selling your personal data for monetary consideration. We consider this information to be a vital part of our relationship with you.

We share your personal data with:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
  • Our trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the Website, database storage and management, conducting crash analytics on the App, e-mail marketing, credit card processing, customer service and fulfilling your orders with us, and analytics and search engine providers that assist us in the improvement and optimisation of the Services, to the extent necessary to supply the Services to you; and
  • Government and law enforcement officials and private parties, where necessary to comply with the law or enforce any legal rights. For example, we may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

We will also disclose your personal data to third parties:

  • If Voisey or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our EULA and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

Where we share your information with third parties as set out above, we put in place contractual or other safeguards to ensure that your personal data is adequately protected and we permit service providers to process your personal data solely for the purposes of providing services to us.

With your express consent, which we will always seek separately, we may share information with third parties whose products or services we think may interest you.

5. Where we store your personal data

We use Google Firebase to host your personal data. For further information on how your personal data is protected through Google Firebase, please click here.

To provide the Services, we may share your personal data within the Voisey group. If you are located in the UK or EEA, this will involve transferring your personal data outside of the UK or EEA. Many of our external third parties are based outside of the UK or EEA so their processing of your personal data will involve a transfer of data outside of the UK or EEA.

Wherever we transfer your personal data outside of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details see here.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the UK or EEA. For further details, see here.

Please contact us at hello@voisey.app if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

The Services may contain advertisements and links to other websites. The fact that we link to another site is not an endorsement, authorization or representation of our affiliation with that third party. Other sites may place their own cookies or other files on your computer, and collect or solicit both personal data and other information from you under rules different from this Privacy Policy. We do not control other sites and cannot be responsible for your experience once you leave our Sites. Therefore, we strongly encourage you to carefully read the privacy policies, terms of use and other policies of other sites you visit.

7. Children

Neither the Website nor the App is intended for, and we do not knowingly accept or collect personal data from, children under 13. If we become aware that a child under 13 has provided us with personal data, we will delete it from our files. If parents or guardians become aware that their minor children have provided us with personal data without their consent (or that we have otherwise collected or obtained such information), they should contact us at hello@voisey.app. We recommend that minors between the ages of 13 and 18 ask their parents for permission before using a credit card or providing any information about themselves to us or anyone else over the Internet.

8. Security

We are very concerned to safeguard the confidentiality and use of your personal data. We employ administrative, physical, technical and organizational measures designed to protect your information from unauthorized access. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to use it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

9. Cookies

Our Website uses Google Analytics to collect information about how users use the Website. These cookies are performance and analytics related cookies.

For further information around how Google may use your personal data through our integration of the Google Analytics tool, please refer to Google's Privacy Policy, which can be accessed here.

You can opt-out from being tracked by Google Analytics in the future by clicking here.

The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full Website.

For more help on cookies generally and how to disable your cookies or delete them visit http://www.allaboutcookies.org or http://www.networkadvertising.org/choices/.

10. Your rights

Upon your request we will remove certain personal data (such as your name or email) held within your account promptly. Please contact hello@voisey.app if you would like for us to do so. You may update your account preferences and your profile within the App.

In addition, if you do not wish to share your GPS or mobile device location information with us, you can choose to turn off such location information within the settings on your mobile device.

We will treat your personal data in accordance with all applicable legislation.

Please be aware that any information or material you may enter in a publicly viewable portion of the Website, such as an online forum or comment section, chat room, or bulletin board, will be readily accessible to the general public. Therefore, you obviously should not enter any personal data or other information or materials that you would not wish to be publicly available into such sections of the App or the Website.

In the event of a personal data breach, we will notify you and any applicable regulator where we are legally required to do so.

EEA users only

If you are located in the EEA, you have a number of rights in relation to how we process your personal data. These include:

  • the right access the personal data that we may hold about you;
  • the right to rectify any inaccurate personal data that we may hold about you;
  • the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; or where you have exercised your right to object to the processing;
  • the right to restrict the processing of your personal data where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
  • the right to object to the processing of your personal data which may be exercised in certain circumstances, for example, where we are processing your personal data for direct marketing purposes, or where your own legitimate interests outweigh ours;
  • the right to have your data ported to a new service provider if you no longer wish to use the Services;
  • the right to complain to your data protection regulator. In the UK that is the Office of the Information Commissioner.

You can exercise any of these rights any time by contacting us at hello@voisey.app. Please note however that these rights don't arise in all circumstances and there are exceptions that apply depending on the personal data in question and what it was being used for.

No fee usually required

You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

California Privacy Rights

In the U.S., the California Consumer Privacy Act ("CCPA") gives California residents certain rights in relation to their personal data and requires the provision by us of some additional information. Any terms defined in the CCPA have the same meanings when used in this section.

This notice is intended to supplement the information provided elsewhere in this Privacy Policy with information specific to California residents.

In the past 12 months, we have collected the following categories of personal information:

  • Identifiers, such as name, postal address, IP address, and email address.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, postal address, telephone number, or payment information.
  • Commercial information, such as a record of products or services purchased, obtained, considered, or other purchasing or consuming histories.
  • Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
  • Geolocation data, such as physical location or movements.
  • Inferences drawn from other personal information, such as a profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The CCPA provides the following rights:

Right to Know: California residents have the right to request information about the categories and specific pieces of personal information we have collected, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. California residents also have the right to request information about our sale or disclosure for business purposes of personal information to third parties.

Right to Delete: California residents have the right to request the deletion of personal information, subject to certain limitations.

Right to Opt-Out of the Sale of Personal Information: California residents have the right to opt out of the sale, as that term is defined in the CCPA, of personal information to third parties. We do not sell personal information to third parties. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

Right to Nondiscrimination: California residents have the right to not be discriminated against for exercising any of these rights.

If you would like to exercise one or more of the above rights, you or your authorized agent can contact us by email at hello@voisey.app or mail using the postal address provided below. We may need you to provide additional information to verify your request, such as providing data elements so that we can confirm they match the information already maintained by us. We will not use this additional information for anything other than handling your request. If you have an unregistered user, we may not be able to verify your identity to a reasonable degree of certainty, and therefore may not be able to fulfill your request. If using an authorized agent, and depending on the circumstances, we may require you to confirm with us directly that you have provided the agent permission to submit your request, or ask the agent to provide proof of signed permission from you.

Additionally, California Civil Code Section 1798.83 permits California residents to request, once a year, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email hello@voisey.app with "Shine the Light" in the subject line of your request.

11. Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.

12. Contact us

Questions, comments and requests regarding this Privacy Policy should be addressed to hello@voisey.app.

Inquiries from EEA or California residents regarding the CCPA or the GDPR can also be sent through this form which will assist you in providing all the required information:

Inquiry concerning privacy and information security

Alternatively, you can contact us by post at:

Voisey Entertainment Limited
The Broadgate Tower
Third Floor
20 Primrose Street
United Kingdom

Any promotional e-mails you receive from us will include specific instructions on how to unsubscribe from our e-mail list, and you may unsubscribe at any time. You may also contact us at any time to update or correct the personal data we have on file for you or to be unsubscribed from all or any particular types of e-mailings.