Privacy Policy

PROMUS Privacy Policy

Last Updated December 2024

Simple Works (L&P) Ltd (trading as PROMUS) (we or us) is a company registered in England and Wales under company number 10627180 with registered office address 124 City Road, London, England, EC1V 2NX.

Our contact details are:

Email: hello@promusapp.co.uk

Post: 124 City Road, London, England, EC1V 2NX

1 What is the purpose of this document?

1.1 We are committed to protecting and respecting your privacy. This privacy policy sets out the basis on which any personal data we collect about users of the PROMUS app (the app) and how that information will be processed by us, in accordance with any applicable law relating to the processing of personal Data, including but not limited to the retained EU law version of the General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the General Data Protection Regulation (EU) 2016/679 (GDPR).

1.2 This privacy policy applies to: users of the app who do not register as well as those who do; any visitors who access our website www.promusapp.co.uk; and all individual contractors and service providers who provide services to our business (you).

1.3 We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.

1.4 Please read this privacy policy carefully to understand what we do with your personal information and what rights you have in relation to our activities.

2 What is personal data and our lawful basis for processing

2.1 Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). We do not process any such special categories of personal data concerning you, nor do we collect any information about criminal convictions and offences.

2.2 We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our processing of your personal data.

2.3 We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.

2.4 Generally, we do not rely on consent as a legal basis for processing your personal data although, if you are a private individual, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by clicking the unsubscribe link in the relevant marketing email.

2.5 We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

2.6 Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

2.7 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 Data we collect about you

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name and username or similar identifier.

Contact Data includes email address and home address.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the app.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses and whether you are an adult or a child user.

Usage Data includes information about how you use the app, products and services.

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

3.3 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.

4 How is your personal data collected?

4.1 We use different methods to collect data from and about you including through:

4.2 Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

4.2.1 purchase our products or services;

4.2.2 create an account on the app;

4.2.3 subscribe to our service or publications;

4.2.4 request marketing to be sent to you; or

4.2.5 give us feedback, make a complaint or contact us.

4.3 Automated technologies or interactions. As you interact with the app or website, we will automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies (as more particularly described at section 11 below), server logs and other similar technologies.

4.4 Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

4.4.1 Technical Data from analytics providers such as Google based outside the EU; and

4.4.2 Contact and Transaction Data from providers of technical, payment and delivery services such as Google based outside the EU.

5 Purposes for which we will use your personal data

5.1 Purpose/Activity

To register you as a new user

Type of data

(a) Identity Data

(b) Contact Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for us to provide the service to you

(b) Necessary for our legitimate interests (to onboard new customers)

5.2 Purpose/Activity

To provide services to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

Type of data

(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for us to provide the service to you

(b) Necessary for our legitimate interests (to recover debts due to us)

5.3 Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

Type of data

(a) Identity Data

(b) Contact Data

(d) Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for us to provide the service to you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

5.4 Purpose/Activity

To administer and protect our business and the app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity Data

(b) Contact Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

5.5 Purpose/Activity

To deliver relevant website content and (in accordance with paragraph 5.9, below) to send marketing communications to you and measure or understand the effectiveness of the marketing we serve to you

Type of data

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(b) Necessary for the legitimate interest of promoting our business and services: You can opt out of receiving marketing communications from us at any time.

5.6 Purpose/Activity

To use data analytics to improve the app, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical Data

(b) Usage Data

Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep the app updated and relevant, to develop our business and to inform our marketing strategy)

(b) Necessary for entering into or performing a contract with you or service for you

5.7 Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Profile Data

(f) Marketing and Communications Data

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business)

5.8 Automated decision-making

5.8.1 Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

5.8.2 We do not envisage that any serious decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

5.9 Marketing

5.9.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

5.9.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

5.9.3 You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing.

5.9.4 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

5.9.5 You can ask us or third parties to stop sending you marketing messages at any by following the opt-out links on any marketing message sent to you.

6 Sharing your information

6.1 We share your personal information with third party contractors and service providers to the extent necessary to provide services to you.

6.2 We may share your information with other third parties as follows:

6.2.1 our regulators, professional advisors, insurance provider and auditors;

6.2.2 HMRC or other government or law enforcement agencies;

6.2.3 if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;

6.2.4 payment service providers if you make purchases via the app;

6.2.5 if we have a legal obligation to do so;

6.2.6 for the purposes of fraud protection and credit risk reduction; and

6.2.7 Meta for advertising purposes and for the creation of Custom Audiences or Lookalike Audiences, all in accordance with stringent data processing terms. Should you wish to be excluded from such processing activities, you will need to change your data privacy settings on Meta. For the avoidance of doubt, for the purposes of the creation of Custom or Lookalike Audiences, the following personal data (email address, first name, last name, residential address) will be shared with Meta (all data will be hashed before sent to Meta), and you are entitled at any time to change your settings on Meta in order to be removed from this process. A hashed list is a coded list that helps Meta show you relevant ads, while also anonymising and protecting your information. Meta's system takes the contact information that it already has and turns it into code to see if it matches the code uploaded from the company. If the code matches, Meta may show a relevant ad. After the match process has been completed, Meta will delete the hashed list. You can learn more about how to change your Ad preferences on Meta by following this link: https://www.facebook.com/help/568137493302217?helpref=faq_content

6.3 The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.

6.4 We also share your data with third-party service providers who provide services to our business, such as our website host server, IT support and maintenance service, cloud storage provider and email exchange server and other businesses that provide certain services on our behalf. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.

6.5 You personal information may also be shared with other users who are members of your "household" within the app.

7 Data security

7.1 We have put in place:

7.1.1 appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed; and

7.1.2 procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transferring information outside the UK or the EEA

7.2 Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: (i) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or (ii) Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK .

7.3 If we are required to transfer your information outside the UK or EEA, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

7.4 If you are based outside the UK or EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to provide the goods/services you have requested from us. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the UK or EEA you agree that such transfer is necessary for us to provides goods/services to you.

7.5 We use Google Analytics to evaluate the performance of the app and website and improve the service we offer you. We may transfer information about you outside the UK or EEA for this purpose. We will only do so where permitted by law.

7.6 We use European Commission approved standard contractual clauses to help protect your personal information when it may be transferred to third countries.

8 How long will we keep your personal information for?

8.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8.3 We keep basic information about our customers (including Contact and Identity) for six years after they cease being subscribers to the app.

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

8.5 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.

8.6 If you have any questions regarding details of retention periods for different aspects of your personal data, please contact using our contact details above.

9 Your rights

9.1 You have the following rights:

9.1.1 to be told what we are doing with your personal information (we do this by providing you with this privacy policy);

9.1.2 to correct or update the personal information we hold about you.

9.1.3 to object to the processing of your personal information;

9.1.4 to request a copy of the personal information we hold about you;

9.1.5 to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;

9.1.6 to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;

9.1.7 to request transfer of your personal information;

9.1.8 to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;

9.1.9 to ask us to send your personal information to another organisation in a computer-readable format;

9.1.10 to complain to the Information Commissioner's office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/.

9.2 Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.

9.3 If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.

9.4 If you want to exercise any of your rights, please contact us using our contact details above. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

10 Third-party links

The app and our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the app, we encourage you to read the privacy notice or privacy policy of every website you visit.

11 Cookies

11.1 This website and our service may place and access certain cookies on your computer. We use cookies to improve your experience of using the website and to improve our range of products and services. We have carefully chosen these cookies and has taken steps to ensure that your privacy is protected and respected at all times.

11.2 All cookies used by this website are used in accordance with applicable laws

11.3 Before the website places cookies on your computer, you will be presented with a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of cookies at any time by selecting the ‘Decline’ option on our website; however certain features of the Website may not function fully or as intended.

11.4 This website may place the following cookies: Strictly necessary cookies - These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. Analytical/performance cookies - They allow us to recognise, distinguish and count the number of visitors, to see request rates, and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.

11.5 You can find the exact list of cookies that we use in the cookies schedule by running a report on the following website, CookieScript: https://cookie-script.com/. The information presented in this report also states the duration for each cookie that is deployed on our website.

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