LEGAL

Anabode Privacy Policy

    TERMS & CONDITIONS | PRIVACY POLICY | COOKIES | DATA SECURITY

    PRIVACY POLICY (June 2020)

    At Anabode, we are committed to protecting and respecting your privacy.

    This policy, along with our Terms and Conditions and any other documents referred to within it, outlines how any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using Our Services, including the Anabode mobile and desktop platforms (“The Apps ”) or visiting our website at www.anabode.co (“Our Site”), you consent to the terms of this Policy and agree to be bound by it and our Terms and Conditions. If you do not agree with this Policy, do not access or use Our Services or interact with any other aspect of our business.

    1. Definitions and Interpretation

    In this Policy, the following terms shall have the following meanings:

    Account : Means an account required to access and/or use certain areas and features of Our Site and The Apps.

    Cookies: Means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below.

    Cookie Law : Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

    GDPR : Means the General Data Protection Regulation ((EU) 2016/679).

    Our Services : The Apps or any of the services accessible through The Apps, Our Site, or any other directly associated platform.

    Our Site : Our website and all associated subpages at www.anabode.co, www.anabode.net and www.anabode.app.

    Personal Data : means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site, or The Apps, or via any other of Our Services. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).

    The Apps : The Anabode web and native apps on mobile, tablet, wearable and desktop platforms used to access an Account.

    We/Us/Our : Means Anabode Limited, a limited company registered in England under company number 09914949, whose registered address is 85 Great Portland Street, London, W1W 7LT, United Kingdom.

    2. Information about Us

    2.1. Our Site and The Apps are owned and operated by Anabode, a limited company registered in England under company number 09914949, whose registered address is 85 Great Portland Street, London, W1W 7LT, United Kingdom.

    2.2. Our Data Protection Officer is Mr Rakesh Thakrar, who can be contacted by email at rakesh@anabode.co.

    3. What does this policy cover?

    This Privacy Policy applies only to your use of Our Site and The App. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

    4. Your Rights

    4.1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

    4.1.1. The right to be informed about Our collection and use of personal data;

    4.1.2. The right of access to the personal data We hold about you (see section 12);

    4.1.3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);

    4.1.4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);

    4.1.5. The right to restrict (i.e. prevent) the processing of your personal data;

    4.1.6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

    4.1.7. The right to object to Us using your personal data for particular purposes; and

    4.1.8. Rights with respect to automated decision making and profiling.

    4.2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

    4.3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

    5. What Data do We collect?

    We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us. This is done based on Art.6 GDPR, which allows the processing of data to fulfil a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our Services only to the extent required to enable you to access our service or to bill you for the same.

    Information We May Collect from You

    We may collect and process the following data about you:

    Information you give us.

    5.1. You may give us information about you by filling in forms through The Apps or on Our Site or by corresponding with us by phone, e-mail or some other means.

    5.2. This includes information you provide when you register to use The Apps or Our Site, create an account, subscribe to the App, upload content to The Apps or Our Site, enter into a tenancy agreement, participate in discussion boards or other social media functions on Our Site, enter a competition, promotion or survey and when you report a problem with Our Site. The information you give us may include:

    a) name;

    b) date of birth;

    c) gender;

    d) Nationality

    e) business/company name

    f) job title;

    g) profession;

    h) contact information such as email addresses and telephone numbers;

    i) demographic information such as post code, preferences, and interests;

    j) financial information such as credit / debit card numbers;

    5.3. You may also you give us information about someone else. If you provide us with personal information about someone else, you must ensure that you are authorised to disclose that information to us and that, without us taking any further steps required by applicable data protection or privacy laws, Anabode may collect, use and disclose such information for the purposes described in this Policy.

    5.4. This means that You must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this Policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information, Anabode’s identity, and how to contact Anabode.

    5.5. Where requested to do so by us, you must also assist us with any requests by the individual to access or update the personal information you have collected from them and entered into The Apps or Our Site.

    5.6. All information is provided at your discretion. You may choose not to provide your personal information or information about others, but it may mean that this restricts your access to our services.

    Information we collect about you.

    5.7. With regard to each of your visits to Our Site we may automatically collect the following information:

    5.7.1. Technical information, including information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use Our Services, the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

    5.7.2. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

    Information we receive from other sources .

    5.8. We may receive information about you if you use any of the other websites we operate or the services we provide. We are also working closely with third parties (including, for example, business partners, third parties who may offer goods or services which we believe may be of interest to you, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.

    Cookies and Other Tracking Technologies

    5.9. Anabode and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g. web beacons, device identifiers and pixels) to provide functionality and to recognise you across different Services and devices. For more information, please see www.anabode.co/cookies which includes information on how to control or opt out of these cookies and tracking technologies.

    6. How do We use your data?

    6.1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

    6.2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in legitimate interests. Specifically, We may use your data for the following purposes:

    6.2.1. Providing and managing your Account;

    6.2.2. Providing and managing your access to Our Services, including The Apps and Our Site;

    6.2.3. Personalising and tailoring your experience on Our Site and in The Apps;

    6.2.4. Supplying Our Services to you or facilitating the tenancy process (please note that We require your personal data in order to enter into a contract with you);

    6.2.5. Personalising and tailoring Our services for you;

    6.2.6. Replying to emails from you;

    6.2.7. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on unsubscribe at the footer of the email)

    6.2.8. Market research; and

    6.2.9. Analysing your use of Our Site and The Apps and gathering feedback to enable Us to continually improve your user experience.

    6.3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

    6.4. Third parties whose content appears on Our Site may use third party Cookies. Please refer to www.anabode.co/cookies for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

    6.5. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

    6.6. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

    6.6.1. the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

    6.6.2. Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

    6.6.3. When establishing and/or reviewing retention periods, the following shall be taken into account:

    a) The objectives and requirements of the Company;

    b) The type of personal data in question;

    c) The purpose(s) for which the data in question is collected, held, and processed;

    d) The Company’s legal basis for collecting, holding, and processing that data; and

    e) The category or categories of data subject to whom the data relates.

    6.6.4. If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

    6.6.5. Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

    6.6.6. In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

    7. How and where do We store your data?

    7.1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

    7.2. Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under GDPR including:

    7.2.1. Ensuring that appropriate technical and organisational measures are in place for treating the data safely and securely;

    7.2.2. Obtaining the explicit and informed consent of the data subject to any data transfer; and

    7.2.3. Ensuring that any data transfer is only necessary for the performance of a contract between us and the data subject i.e. for the services to be provided and no other reason; and

    7.2.4. Ensuring that any transfer is necessary for the performance of a contract made in the interests of the data subject between us and another party.

    7.3. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site and provided through our Services.

    7.4. Anabode is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Steps We take to secure and protect your data include:Steps We take to secure and protect your data include:

    Technical Data Security Measures:

    7.4.1. All emails containing Personal Data must be encrypted;

    7.4.2. All emails containing Personal Data must be marked ‘confidential’;

    7.4.3. Personal Data may only be transmitted over secure networks;

    7.4.4. Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;

    7.4.5. Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;

    7.4.6. Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;

    7.4.7. Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy;

    7.4.8. All Personal Data transferred physically should be transferred in a suitable container marked “confidential”;

    7.4.9. No Personal Data may be shared informally and if access is required to any Personal Data, such access should be formally requested from the DPO;

    7.4.10. All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely;

    7.4.11. No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;

    7.4.12. Personal Data must be handled with care at all times and should not be left unattended or on view;

    7.4.13. Computers used to view Personal Data must always be locked before being left unattended;

    7.4.14. No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the DPO and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;

    7.4.15. No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;

    7.4.16. All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted;

    7.4.17. All electronic copies of Personal Data should be stored securely using passwords and encryption;

    7.4.18. All passwords used to protect Personal Data should be changed regularly and should be secure;

    7.4.19. Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

    7.4.20. All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;

    7.4.21. No software may be installed on any Company-owned computer or device without approval; and

    7.4.22. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the DPO to ensure that the appropriate consent is obtained and that no data subjects have opted out.

    Organisational Data Security Measures

    7.4.23. The following organisational measures are in place within the Company to protect the security of personal data:

    7.4.24. All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s GDPR Policy;

    7.4.25. Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;

    7.4.26. All employees and other parties working on behalf of the Company handling Personal Data will be appropriately trained to do so;

    7.4.27. All employees and other parties working on behalf of the Company handling Personal Data will be appropriately supervised;

    7.4.28. All employees and other parties working on behalf of the Company handling Personal Data should exercise care and caution when discussing any work relating to Personal Data at all times;

    7.4.29. Methods of collecting, holding, and processing Personal Data shall be regularly evaluated and reviewed;

    7.4.30. The performance of those employees and other parties working on behalf of the Company handling Personal Data shall be regularly evaluated and reviewed;

    7.4.31. All employees and other parties working on behalf of the Company handling Personal Data will be bound by contract to comply with the GDPR and the Company’s GDPR Policy;

    7.4.32. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s GDPR Policy;

    7.4.33. Where any agent, contractor or other party working on behalf of the Company handling Personal Data fails in their obligations under the GDPR and/ or the Company GDPR Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

    8. Do We share your data?

    8.1. In order to provide our integrated services to you, We may be required to share your data with the third parties as noted in 6.4 of this Policy.

    8.2. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.

    8.3. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

    8.4. We may compile statistics about the use of The Apps and Our Site, including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

    8.5. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR by such data processors. These data processors include:
    8.5.1 Google
    8.5.2 Stripe
    8.5.3 Userlike
    8.5.4 Quickblox

    8.6. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

    9. What happens if Our business changes hands?

    9.1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

    9.2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.

    10. How can you control your data?

    In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site or The Apps, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

    11. Your right to withhold information

    11.1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

    11.2. You may restrict Our use of Cookies. For more information, please see www.anabode.co/cookies.

    12. How can you access your data?

    You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at support@anabode.co or using the contact details below in section 13.

    13. Contacting Us

    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@anabode.co. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

    14. Changes to Our Privacy Policy

    We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site or The Apps following the alterations. If the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We encourage you to review our privacy policy whenever you use Our Services to stay informed about our information practices and the ways you can help protect your privacy.