Mobile Application Privacy Policy

Consent to Installation of the App

Under 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.

By installing and registering on this App, you are indicating your consent to the processing of your personal data (including your name, contact details and Device information).

How you can withdraw consent

Once you provide consent by registering the app, you may change your mind and withdraw consent at any time by contacting us for support but that will not affect the lawfulness of any processing carried out before you withdraw your consent. You acknowledge however that the revocation of your permission might impact the proper functioning of the App.

Consent to processing Location Data

By clicking “Register” I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated).

By clicking “Exit” I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Location Data

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

Introduction

This policy (together with our end-user Mobile Solution Service Agreement (MSSA) and any additional terms of use incorporated by reference into the MSSA applies to your use of:

• Crystal Ball Remote Workforce Management mobile application software (App) once you have downloaded a copy of the App onto your mobile telephone or handheld Device (Device).
• Any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Important information and who we are

Crystal Ball Ltd is the owner of the App (collectively referred to as “we”, “us” or “our” in this policy).

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

Contact details

Our full details are:

• Full name of legal entity: Crystal Ball Limited
• Data Protection Officer email dpo@crystalball.tv
• Postal address: Washbrook House, Talbot Road, Stretford, Manchester M32 0FP

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

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 on 25^th April 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, available to you when you install the App.

Purpose of data collection

We may collect, use, store and transfer different kinds of personal data about you to comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or your or third parties), and detect malicious activity. In particular, we use your data for the following purposes:

• Device permissions for personal data access, analytics, registration and authentication provided directly by this App;
• The App sends out personal data that can be viewed on our portal and in the (Alarm Receiving Centre) ARC, as well as within this App. This data may be shared with your employer, in relation to the provision of our services provided under a separate agreement with your employer and may be shared with emergency services in the event of an emergency incident. We may also use such data to analyse how users are using our software products to help us make informed product decisions when implementing changes.
• We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal data processed via the App and such data is handled securely, including encrypted transmission over HTTPS.
• The App may request certain permissions that allow it to access your Device Data (as described below).
• If you grant any of the permissions listed below, the respective personal data may be processed (i.e. accessed, collected, used and shared) by the App:

Location Data

• The App requires fine location to gather GPS information that is sent with application messages to our Portal and ARC to be used for locating a User should they raise an alarm or have an activity expire.
• The App requires coarse location to acquire Wi-Fi SSID in addition to aiding finding a User raising an alarm or in an overrun activity.
• The App requires background location to enable automatic position and manual positions when using the Bluetooth Button accessory, including when the App is closed or not in use.

Camera & Storage Permission

• This will be needed for accessing the camera or capturing images with regards to the Geotagging function.

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 your employer.
• 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.

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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

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.

Data Retention

In some circumstances you can ask us to delete your data: see below for further information.

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.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

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.

Your responsibility

You acknowledge that you remain responsible for any third party personal data obtained, published or shared through this App and confirm that you have the third party’s consent to provide such data to us.

Glossary

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 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 with your employer.

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.

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.
• 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.

Description of categories of personal data

• Identity Data: first name, last name, username or similar identifier.
• Contact Data: email address and telephone numbers.
• Device Data: includes the type of mobile Device you use, a unique Device identifier such as the IMEI number.
• Content Data: includes information stored on your Device, including login information and any digital content.
• Profile Data: includes your username and password.
• Usage Data: includes details of your use of any of the App including, but not limited to, network traffic data and other communication data.
• Location Data: includes your current location disclosed by GPS on your phone.