1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and website service users. We understand that your personal data is a matter of paramount importance and we retain the utmost professional standards to ensure that your data is kept safe and secure.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and website service users. This means that it is us that determine the purposes and means of the processing of your personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, "we", "us" and "our" refer to Better Management Limited, a company incorporated in England and Wales with company number 11156720 whose registered office is at 86-90 Paul Street, London, EC2A 4NE.
1.5 You can contact us via the address stated above, or by emailing: [email protected]
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version and operating system. The source of the usage data is our website host. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services. We do not combine your usage data with other personal data.
2.3 We may process your account data ("account data"). The account data includes your full name, your email address and your telephone number. The source of the account data is supplied directly by you upon registering an account with us (whether that is inputted directly by you or automatically populated based upon your account with a third-party that we are integrated with, such as Facebook or Google).
On the one hand, the account data is processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us.
We may also process your account data for marketing purposes. This will only happen when you have provided us with your express consent to receive marketing (and this will include the specific method(s) that we may use to contact you). Furthermore, our third-party business customers who manage venues, premises etc. will ask whether you wish to receive marketing communications from them too. You can provide your express consent at the stage. At all times, you can unsubscribe from any marketing that you receive either by us or our third-parties by simply unsubscribing using the “one-click” unsubscribe function via the method that you are contacted with.
For the avoidance of doubt, we remain committed to complying with all data protection laws, and will never process any of your account data for marketing-purposes (or similar) unless you have provided your express consent.
2.4 We may process your information generated via your profile on our website ("service data"). The service data may include the time of check-in and/or check-out based on a per-location basis within a 28-day time period. The profile data may be processed for the purposes of enabling your use of our website and services. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us.
2.5 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and for our required record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, the business and the communications with users.
2.6 We may process any of your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 It is important that you are aware that we disclose your account data and service data to selected third-party venue operators. We only disclose this personal data to venue operators who you are optionally and voluntarily choosing to attend which necessitates the use of our website and the website solution. This enables the venue operators to fulfil their own legal obligations in respect of knowing who has entered their premises and for how long, and to report the same to the respective authorities. Apart from what is set out at paragraph 2.3 above, a third-party venue operator is strictly prohibited from using your account data and/or service data for marketing (or similar) purposes. Any such third-party venue operator is a processor of your personal data and is subject to strict, industry-standard, security requirements in respect of the storage and security of your personal data, in accordance with the provisions of this policy.
3.2 Your personal data is also shared with other third-party suppliers necessary to ensure that our website is operative, live and fully functional (such as Amazon Web Services). Any such third-parties are subject to contractual obligations to: (i) only process the Personal Information in accordance with our prior written instructions; (ii) not use the Personal Information for their own purposes; and (ii) use appropriate measures to protect the confidentiality and security of the Personal Information; together with any other additional requirements we have or that are available under applicable law.
3.3 In addition to the specific disclosure of personal data set out directly above, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4. Security
We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage. The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal information. Where you have chosen a password which allows you to access certain parts of the Services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for our Services. We will not be liable for any unauthorised use of using your name and password and/or the website.
5. International transfers of your personal data
5.1 We do not transfer your data outside of the European Union.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) service data is retained for a period of 28 continuous days only;
(b) account data is retained for a period until you decide to either unsubscribe from marketing (where you have provided your express consent previously) or where you cancel your account. Upon cancellation of your account, your personal data will be deleted within 28 days.
(b) usage data (web logs) is retained for a period of 1 year;
(c) communication data is retained for a period of no more than six years.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We will notify you of changes to this policy by email. Your continued usage of our website after this notification is your deemed acceptance. If you do not accept the changes, you must not use our website.
8. Your rights
8.1 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.2 You may exercise any of your rights in relation to your personal data by written notice to us as set out at the end of this policy. Please note that there are limitations and exceptions that apply to the above rights.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication - we use cookies to identify you when you visit our website and as you navigate our website;
(b) status - we use cookies to help us to determine if you are logged into our website; and to facilitate the user journey
(c) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
11. Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies.
The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
12.2 If you block cookies, you may not be able to use all the features on our website.
13. Contact us
You might have some questions or concerns with your personal data at checkincognito and we would be more than happy to resolve these. Please email us at [email protected] and we will aim to get back to you within 24 hours. You can also write to us at our address as stated at the start of this policy.
14. Complaints
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Website: www.ico.org.uk
