Last updated 28th March 2023
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1. About this privacy statement
1.1 Who’s who
More Human ("we") are committed to protecting and respecting your privacy and keeping your personal information secure.
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This policy describes how we use the personal information that we collect from you in connection with your receipt of our products and services (the “Services”) and when you interact with our websites and apps (together, the “Websites”).
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When this Privacy Policy uses the term "Organiser" we mean event creators using the Services to create events for consumers using our Services (a) to consume information about, or attend, events ("Consumers"), or (b) for any other reason. Organisers, Consumers and third parties using our Services are all referred to in these Terms collectively as "Users", "you" or "your".
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Please take a moment to review this policy in detail. As you will see, it explains our privacy practices and covers the following areas:
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1. About this privacy statement
2. Information we may collect about you
3. How and on which basis we use your personal information
4. Our use of cookies
5. Disclosure of your personal information
6. How we hold and protect your personal information
7. Your rights
8. Links to other websites
9. Changes to our privacy policy
10. Contact us
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1.2 More Human as a data controller and a data processor
EU and UK data protection laws make a distinction between organisations that process Personal Data for their own purposes (known as "data controllers") and organisations that process personal data on behalf of other organisations (known as "data processors"). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
More Human may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances.
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For example, if you create an account with us to organise your events, More Human will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Websites, which could relate to Organisers or Consumers. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about events we think may be of interest to you. In this case, the data controller is More Human Technology Ltd, trading as More Human of 12 Sabella Court, Mostyn Grove, London E3 2ET, UK . You can contact us at the "Contact us" section below.
However, if you register for an event as a Consumer, we will process your Personal Data to help administer that event on behalf of the Organiser (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Organiser target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness of various sales channels, etc.). In these circumstances, More Human merely provides the tools for Organisers; More Human does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy of any Personal Data provided. In this case, More Human is the data processor, not the data controller. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organiser as the data controller, not to More Human. Organisers can find additional information in the Organiser Data Processing Agreement included in our Terms of Service, section 16.
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2. Information we may collect about you
2.1 Personal data that we collect
Summary:
We collect information about you when you:
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Create an account;
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Use the Platform;
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Attend an event;
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Reply to an event email;
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Visit our website; and
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Communicate with us.
We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies.
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If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.
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When you use or interact with us through the Services or engage with More Human as a sales customer or prospect, we may collect Personal Data. Sometimes this will be on our own behalf and other times this will be on behalf of an Organiser using our Services to run an event. This is an important distinction for purposes of certain data protection laws and is explained in more detail below.
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2.2 Information collected from all users
We may collect and process the following personal data about you:
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Information that you provide to us
We collect information from you when you fill in forms on events.more-human.co.uk or more-human.co.uk (including when you register to use our Services), when you respond to any surveys that we send to you to complete, post materials on the Websites, request further information about the Services and when you report a problem with our Websites. This information may include:
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your name;
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your email address and telephone number;
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photos you provide
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profile information you provide
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details of any opinions or complaints you raise regarding the Service (including those posted on public forums and social media) and details of any correspondence that you have with us, including via email and our customer support telephone hotline;
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your responses to any surveys or questionnaires that we may send to you;
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details of transactions you carry out through our Websites and of the fulfilment of your orders. All payments are made through our payment processors (see Section 5.1 Payments via our websites). All card details are provided direct to the payment processor and we only receive transaction details and certain limited card details (name, address, card type, last four digits of card number and expiry date) from the payment processor to manage your payments and to identify your transactions; and
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your preferences in receiving marketing communications from us.
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Other information we collect about your visit to our website or use of our apps
With regard to each of your visits to our Websites, we may automatically collect details of your visit, including, but not limited to, traffic data, location data, weblogs and other communication data. We may also collect information about your computer, including where available your IP address, operating system and browser type, for system administration, and for analysis of how users are using our Websites. We may also collect details of the resources that you access on our Website. See '4. Our use of cookies' below for more information.
We may also collect, use and share anonymised data and aggregated data such as statistical or demographic data for any purpose. Anonymised and aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate statistics to understand usage of our Websites.
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We do not 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). Nor do we collect any information about criminal convictions and offences.
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2.3 Information collected from consumers
If you are a Consumer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of an Organiser.
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Information you provide via the Websites
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If you register for a paid event, you will provide financial information (e.g., your credit card number and expiration date, billing address, etc.) some of which may constitute Personal Data.
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In addition, Organisers can set up event registration pages to collect virtually any information from Consumers in connection with registration for an Organiser's event listed on the Services.
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More Human does not control an Organiser's event registration process nor the Personal Data that they collect. When you register for, or otherwise provide information to More Human in conjunction with an Organiser event or activity, whether that information is yours or a third party’s, in connection with a purchase, registration, or transfer, that Organiser will receive and may use the information you provide. Please see Section 5.2 below, titled “Disclosure of your personal information: Organisers” for more information about an Organiser’s receipt and use of your Personal Data.
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Information we obtain from other sources
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Third parties: We may also collect or receive Personal Data from third party sources, such as Organisers, other Consumers, social media or other third party integrations.
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User content: We may receive information about you when you or another user uploads photos or posts other content to the Platform, or replies directly to event emails sent via the Platform.
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3. How and on which basis we use your personal information
We will only use your personal information for specific purposes and when we have a lawful basis to do so. Most commonly, we will use your personal data in the following circumstances:
3.1 To perform a contract with you or to take steps at your request prior to entering a contract with you
We use your personal information to enter into and perform our contracts, including:
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to provide you with information or services that you request from us;
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to provide you with access to the Services, including to register you as a user of the Services and to enable you to set up an account and to sell tickets via the Services;
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to determine your eligibility for our Services;
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to provide the functionality of the Services that you have requested via our Websites;
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to send you service notifications;
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to notify you about the communications of other users to you about your events;
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to allow you (or the corporate client you represent) to participate in interactive features of our Services, when you choose to do so;
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to notify you about changes to our Service; and
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to manage our relationship with you.
3.2 When you have given us your consent to use your personal information
We use your personal information when you have given your consent for us to process your personal information:
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to allow us to set cookies and other similar technologies which provide information about your online behaviour and browsing patterns which we use for the purposes of targeted marketing and advertising;
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to allow us to set cookies and other similar technologies which provide information about your online behaviour and browsing patterns which we use for the purposes of analysing use and movement around our Websites so that we may improve our Services and our Websites; and
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to send you marketing communications by email if your consent is required. If we are sending you information about our services and products that are similar to those that you have already purchased, we will rely on soft opt-in consent which we can take as given because you have signed up for our similar services already.
3.3 To comply with our legal obligations
We use your personal information to comply with various legal and regulatory obligations, including:
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to notify you about changes to our terms or privacy policy; and
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to comply with mandatory law enforcement or regulatory requests for the disclosure of your personal information, including in circumstances of suspected fraudulent activity
3.4 To fulfil our legitimate interests and your interests and fundamental rights do not override those interests
We use your personal information in order to deploy and develop our services, to improve our risk management and to defend our legal rights, including:
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to ensure that content from our Website is presented in the most effective manner;
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to administer our site and for internal operations, including troubleshooting, data analysis, research and statistical purposes;
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as part of our efforts to keep our Website safe and secure and to monitor actual or suspected fraudulent activity;
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to train our staff;
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to carry out retargeting advertising;
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to measure the effectiveness of our Services so that we can improve our Services;
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analysing your habits and movement between pages when you visit the Websites so that we may improve our Services and our Websites;
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to send you information about the Services that you are receiving and any changes to such Services and new features that you need to be aware of;
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to provide you with information about new features of the Services that you are receiving and about our services and products that are similar to those that you have already purchased or enquired about; and
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to build profiles of potential purchasers of our products and services and to identify potential purchasers of our products and services.
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3.5 Marketing, targeted advertising and opting out
You will only receive our marketing communications if we can lawfully send them to you, that is:
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when you have specifically consented to receive them;
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if you have already purchased our products and services, we may send you information about our similar products or services under soft opt-in consent; and
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in your business capacity if you have requested information from us, if you provided us with your details or if we have identified you as someone who may be interested in our products/services.
We use third-party advertising platforms, such as Facebook, Google etc. to send you advertising messages that are targeted at you. See ‘4. Our use of cookies’ below for more information.
You can opt-out of our direct marketing at any time by:
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unsubscribing from our marketing messages by following the opt-out links on any marketing email sent to you or by emailing support@more-human.co.uk; and/or
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telling us you do not wish to receive targeted advertising by emailing support@more-human.co.uk
3.6 Payments and Profiling
Our payment processors (see Section 5.1 Payments via our websites) use technology to help them make decisions about financial transactions and your card payments which may prevent you from accessing our Services or continuing to use our Services. In this role, our Payment Processors act as controller and may monitor insights and patterns of payment transactions and other online signals to reduce the risk of fraud, money laundering and other harmful activity. This activity is carried out in accordance with their privacy policies available at the links below:
4. Our use of cookies
Our Websites use cookies and other similar technologies to distinguish you from other users of our Websites. Some cookies are necessary to allow our Websites to function, others help us provide you with a good experience when you browse our Websites, others allow us to collect data to improve our sites and others are for the purposes of targeted advertising.
4.1 Retargeting
Our Websites use retargeted advertising. As a result of this retargeting, you may see ads for our services on other sites such as Facebook. Our retargeting providers will read a cookie that is already in your browser, or they will place an anonymous cookie or ‘pixel’ in your browser when you visit our Websites.
4.2 Analytics
We use analytics services (including Google) in order to better understand our users’ needs and to optimize our Service and experience. These are technology services that help us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Service with user feedback. The analytics services use cookies and other technologies to collect data on your behaviour and your devices (eg device's IP address, device screen size, device type (unique device identifiers), browser information, geographic location, preferred language). For details of Google’s privacy practices, see Google Analytics privacy information.
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You have choices as to which cookies you agree to. Please see our Cookies page to find out about the cookies we use, what they are used for and how to set or change your preferences in relation to cookies.
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5. Disclosure of your personal information
5.1 Payments via our websites
All payments through our Websites are made using the payment services provided by Stripe or GoCardless (Payment Processor). To use these payment services you must have your own account with the Payment Processor and have connected your account with our Services. To provide your card and billing details, you will be directed to a Payment Processor’s service.
In processing card payments, the Payment Processor acts as a data processor to us but in other respects, both we and the Payment Processors act as data controllers and we will share personal information with the Payment Processors and the Payment Processors will share personal information with us in order to provide the Services. For further information on how the Payment Processors handle your personal data see:
5.2 Organisers
In addition, when you register for an event, sign up for communications, or otherwise input your Personal Data (such as through a web form or via direct reply to event emails) to communicate with an Organiser or participate in an Organiser event, that Organiser will receive that information. For instance, if you input your name and email address into a web form for an Organiser offer, activity or event, the Organiser will receive that information. The Organiser may then send you marketing or other communications, which may be subject to its own, separate privacy policy. Likewise, if you provide your mobile phone number, you may receive information messages related to the service, event, activity or information in which you’ve expressed interest.
When you purchase tickets to, register for or donate to an event, transfer an event ticket or registration to another person, opt-in to analytics cookies on our Websites, or otherwise input your Personal Data (such as through a web form), or otherwise communicate with an Organiser, or participate in or express interest in an Organiser or Organiser event or activity, that Organiser will receive the information you provide, including your Personal Data, and where a ticket or registration is transferred, the Personal Data of the transferee as well. Other third parties that are involved in or on whose behalf an event or activity is promoted, may receive that Personal Data as well. For example, as to branded events, we may provide your Personal Data both to the Organiser charity or business branding the event and the Organiser group who is hosting the event. In some instances, an Organiser may appoint a third party, which may or may not be affiliated with the Organiser, to create an event on its behalf (we call these third parties ("Third Party Organisers").
For example, and without limitation, a community centre (the Organiser, in this case) may allow third party promoters or activity providers (the Third Party Organisers) to create events that will be hosted at the Organiser's venue using its More Human account. In that case, we may provide your Personal Data to the Third Party Organisers on behalf of the Organisers.
We are not responsible for the actions of these Organisers, or their Third Party Organisers (or other downstream recipients of your Personal Data), with respect to your Personal Data. It is important that you review the applicable policies of the Organisers, and if applicable and available, their appointed Third Party Organisers, of an event (and the related fundraising page, if applicable) before providing Personal Data or other information in connection with that event or related fundraising page. Similarly, if you are a member of an Organiser's organisation or group within More Human, your Personal Data will be available to the Organiser and shared with those Third Party Organisers granted permission by the Organiser to view all members of the Organiser's organisation.
5.3 Others with whom we may share your personal information
We share limited personal data with our affiliates only to the extent required to provide our Services and for internal administration purposes.
We may disclose your personal information to selected third parties, including:
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Third party service providers who we use to help manage our business. We only share information with the following service providers;
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Emails: Postmark (https://postmarkapp.com/) - Postmark ‘powers’ all of our automatic emails - any notifications (e.g. new booking, cancellation) from More Human.
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Customer support: Hubspot (https://www.hubspot.com/) - We use your contact details (email, phone number) to provide you with support for using More Human. It means we can respond to your questions via email or phone.
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Web and mobile analytics: Google Analytics (https://analytics.google.com/analytics/web/provision/#/provision)
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Website hosting: Wix (https://www.wix.com/) and Bubble (https://bubble.io/)
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Survey forms: Google Forms (https://www.google.co.uk/forms/about/) and Typeform (https://www.typeform.com/)
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Insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims;
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If More Human or substantially all of its assets are acquired by a third party, to the relevant third party (and its advisers) who may use the data in connection with the acquisition;
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Taxation authorities, regulators, law enforcement agencies or other authorities if required by such authorities or by due process of law.
6. How we hold and protect your personal information
6.1 How we keep your personal information secure
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
All information you provide to us is stored on external servers monitored by Amazon Web Services, or Google, or Wix. Any payment transactions will be carried out by our Payment Processor over encrypted connections using SSL technology. Unfortunately, the transmission of information via the internet is not completely secure and any transmission is at your own risk.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6.2 Our retention of your personal information
We will retain your personal data for as long as necessary to provide you with our services and for so long as you do not wish to unsubscribe from our marketing communications or from receiving targeted advertising. We will also retain your personal data as necessary to fulfil our contractual obligations and to comply with our legal obligations, resolve disputes, and enforce our agreements.
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Where we no longer need to process your personal data for the purposes set out in this Privacy Policy, we will delete your personal data from our systems unless we need to retain a limited amount of information to make sure that we act in accordance with your wishes. Where permissible, we will also delete your personal data on your request. Information on how to make a deletion request can be found in the section, Your rights.
Please email support@more-human.co.uk if you would like details of our retention periods for different kinds of personal data.
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6.3 International transfers of your personal information
Your personal information will be processed by us in the UK and the European Economic Area (“EEA”). We take steps to minimise transfers of your personal information outside of the UK and EEA, however, there may be some circumstances where we or our service providers do transfer your personal information to a destination outside the UK or EEA.
We will only transfer your data outside of the UK and the EEA in compliance with data protection laws and provided appropriate safeguards to protect personal information being transferred are in place, such as an adequacy decision, approved model contractual clauses or binding corporate rules.
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Please contact us using the details set out in the “Contact us” section below if you would like details of the specific safeguards applied to the export of your personal information.
7. Your rights
You have certain legal rights with respect to your personal information depending on your location and applicable laws. You may exercise your rights at any time by contacting us at support@more-human.co.uk.
7.1 Your rights if you are resident in the UK or the EEA
Right of access: You have the right to access any personal data we hold about you: we will provide a copy of your personal data that we hold together with details of the purposes of the processing, the types of personal data we hold and the people to whom your personal data has been disclosed.
Right to rectification: You have the right to have inaccurate or incomplete personal data corrected or to restrict the processing of personal data whilst the accuracy is checked.
Right to erasure: You have the right to ask to have personal data we hold about you erased. 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 law.
Right to data portability: In certain circumstances, you have the right to have data we hold about you transferred to yourself or another data controller. Note, this right only applies to information that is processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to object: You have the right to: ask us not to process your personal data for direct marketing purposes; object, on grounds relating to your particular situation, to the processing of your personal data (including profiling) where we are relying on a legitimate interest.
Right to withdraw consent: You have the right to 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.
Right to complain: You have the right to lodge a complaint with the UK Information Commissioners Office or other data protection supervisory authority applicable to you if you are unhappy with the way we are handling your personal data.
7.2 Your rights if you are a resident of California
How We Collect, Use, and Disclose your Personal Information.
The Information we may collect about you section describes the personal information we may have collected over the last 12 months, including the categories of sources of that information. We collect this information for the purposes described in the How and on which basis we use your personal information; section. We share this information as described in the Disclosure of your personal information; section. We use cookies, including advertising cookies, as described in the Our use of cookies section; and on our Cookies page.
Your CCPA Rights and Choices.
As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:
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Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
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the categories and specific pieces of personal information we have collected about you;
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the categories of sources from which we collected the personal information;
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the business or commercial purpose for which we collected the personal information;
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the categories of third parties with whom we shared the personal information; and;
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the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
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Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
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Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
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Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
7.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
7.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. Links to other websites
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
9. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and we will notify you of any material changes to this policy through our website or other usual communication channels. We recommend that you review this page from time to time for updates.
10. Contact us
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@more-human.co.uk.
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