Privacy Policy

Introduction

This policy, together with our Terms of Use (Terms of Use) applies to your use of the Challenge Social mobile application software (App) which has been created for use on your mobile telephone or handheld device (Device).

Challenge Social allows you to create, participate in and share challenges with your friends and family along with creating individual leader boards and holding the data/scores of any competitive scenario in your life. 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. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

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

Challenge Social Ltd is the controller and is responsible for your personal data (collectively referred to as "Challenge Social", "we", "us" or "our" in this policy). If you have any questions about this privacy policy, you can contact us using the following details:

Email address: privacy@challengesocial.com

Postal address:

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 on 8 July of 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. 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.

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 may, from time to time, contain links to and from the websites of our partner 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 these policies before you submit any personal data to these websites or use these services.

  • Identity and Contact Data

    This includes the information you give us when you register to use the App. We will ask for your full name, date of birth, gender, username and a password, email address and telephone number.

  • Device Data

    This is information that is collected automatically when you use our App. It includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device, mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.

  • Content Data

    This includes information stored on your Device, including friends' lists and contacts, photos, videos and other digital content that you might want to share on the App or use to invite others to use the App. You can choose whether you allow us to access your camera and contacts. We may also receive details of your friend lists if you use third-party integrations such as Facebook, Instagram and Snapchat to invite friends to use the App.

  • Profile Data

    This includes the information you choose to put in your biography, the content and communications you share with others through the App and the challenges that you set up or participate in. We do not expressly 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). However you may chose to provide such information in your biography, which can be made public or private. Special Categories of Personal Data are subject to special protection under EU law.

  • Usage Data

    This information is collected automatically when you use our App. It includes details of your use our App, such as the type of content you view or engage with, the features you use, the other users you interact with and the time, frequency and duration of your activities.

  • Location Data

    This refers to your current location disclosed by GPS technology. We also use GPS technology to determine your current location. Some of our location-enabled features require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

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 or participating in certain types of challenges. 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.

Information we receive about you from other sources

We will receive and analyse content, communications and information that other users provide when they use the App. This can include information about you, for example when others send a message to you or share or comment on photos with you.

We may also receive Device Data from third party analytics providers such as Google Analytics.

Cookies

We use cookies to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App and Our Sites. We also use cookies to display advertisements that we think might interest you. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We do not share your personal data with any third party for direct marketing purposes.

We use the information that we collect from you for the following purposes:

  • To install the App and register you as a new App user. The legal basis for this is your consent. You can withdraw this consent at any time by deleting your account on the App.
  • To enable you to use the App and all of its features. The legal basis for this is the performance of a contract. However some features will require specific consent, such as accessing content on your Device. Where you provide consent you have the right to withdraw that consent at any time.
  • To manage our relationship with you including notifying you of changes to the App, this Privacy Policy or our Terms of Use. We will also use your information if you contact us in order to respond. Our lawful basis for using your information in this way is the performance of a contract, and is also necessary to comply with legal obligations.
  • To analyse how our users user the App and monitor trends. We rely on legitimate interests for this processing and it helps us to develop the features available, test and improve the App and grow our business.
  • To administer and protect our business and this App including troubleshooting, data analysis and system testing. We rely on legitimate interests to secure our App, provide administration and IT services and ensure a good experience for users.
  • To deliver relevant advertisements to you about goods or services that may interest you. This is necessary for our legitimate interests to monetise our App and grow our business. We use Google Admob to deliver adverts which are targeted towards your interests.

Your information is shared with others in the following ways:

  • Other users and accounts that you interact and communicate with.

    When you use features of the App you can choose who can see your challenges, posts and other information. These can be set to either public or private. Other users with whom you connect can see your position in the Leader board and if you send messages through the App then the recipient can see the content that you send. Other users can re-share content that you have provided to them with other users in their network with whom you are not connected. You should therefore carefully consider who you share content with.

  • Third-party integrations

    If you choose to use third-party apps which are integrated with our App (such as Facebook, Instagram, and Snapchat) then the third party may receive information about you. This information will be governed by the third party’s own privacy policy.

  • New owner of the App

    We may choose to sell, transfer or merge parts of our business or our assets to or with a third party. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then we may transfer your information to the new owner.

  • Third party partners and service providers

    We may share your information with service providers acting as processors who provide us with IT and system administration services. We may also share your information with our professional advisers including lawyers, bankers, auditors and insurers.

    We provide aggregated data to advertisers and other partners to help them better understand our audience and for market research purposes. However we do not share any information that will personally identify you.

    Where we use a partner to provide ad serving technology (such as Google Admob) to provide advertisements of interest to you within the App, our partners may collect and use Device Data. This information will be used in accordance with their own privacy policy. More information on Google Admob can be found here: https://admob.google.com/home/

Our servers are based in the UK and we do not host your personal data outside the European Economic Area (EEA). However some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring 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.
  • Where we use certain service providers, we may use standard contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

All information you provide to us is stored on our secure cloud based servers. You will have chosen a password that enables you to access the App. 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.

Ensure that when you are using public features of the App or sharing information that you do not submit any personal data that you do not want to be seen, collected or used by other users.

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.

We will hold your data whilst your account is active. An account is active until you delete it or you have not logged in for 10 years, whichever comes first. You can delete your account by going to Settings within the App.

When you delete your account we will delete all of your content and you will no longer be able to log in or access it. However please note that content you have shared with other users will not be deleted.

In some circumstances you can ask us to delete your data without deleting your account: see Your legal rights

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.

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).

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.

Any Challenge that is uploaded to Challenge Social MUST NOT include:

  • Cartoon or Fantasy Violence
  • Realistic Violence
  • Prolonged Graphic or Sadistic Realistic Violence
  • Graphic Sexual Content and Nudity
  • Unrestricted Web Access
  • Gambling and Contests
  • Profanity or Crude Humor
  • Mature/Suggestive Themes
  • Horror/Fear Themes
  • Medical/Treatment Information
  • Alcohol, Tobacco, or Drug Use or References
  • Simulated Gambling