FOBBS Privacy Policy

INTRODUCTION

Welcome to the FOBBS privacy policy.

FOBBS respects your privacy and is committed to protecting your personal data. This privacy policy (together with our App Terms) tells you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy together with our App Terms as set out at https://www.fobbs.uk/fobbs-terms.pdf and any additional terms of use incorporated by reference into the App Terms aims to give you information on how FOBBS processes any personal data we collect from you (either directly or via third parties), or that you provide to us through your use of our App. We may receive your personal data via the following routes: (i) Direct interactions. You may give us your Identity and Contact Data by registering as a User and creating a user profile on our App, or where we enter into a contract with you in respect to providing you with Services; (ii) Automated technologies or interactions. As you interact with our App, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns; and (iii) Third parties or publicly available sources. Further details on the ways in which we may receive your personal data is set out in section 3 below.

We do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Figures of Black British Society or FOBBS, is a trading name of Junction 5 Studios Limited (FOBBS, we, us or our in this privacy policy) is the controller of your personal data meaning we are the organisation legally responsible for deciding how and for what purposes it is used. We collect, use and are responsible for certain personal data about you. When we do so we are subject to UK data protection law, including the UK General Data Protection Regulation (UK GDPR).

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Junction 5 Studios Limited
Email address: hello@fobbs.uk
Postal address: 63/66 Hatton Garden, Fifth Floor Suite 23, London, England, EC1N 8LE

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next log onto the App. The new policy may be displayed on screen and you may be required to read and accept the changes to continue your use of the App.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The App 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 policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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).

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, username, age range or similar identifier.
  • Contact Data includes email address and telephone number.
  • 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 our App.
  • Profile Data includes your username, your interests, preferences, feedback and/or survey responses.
  • Usage Data includes details of your use of our App.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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

  • Direct interactions. You may give us your Identity and Contact Data by registering as a User and creating an account on the App, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • reach out to us through other means, such as social media;
    • request marketing to be sent to you; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with the App, we will automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using usage and feedback logs and other similar technologies.
  • Third parties. We will receive personal data about you from various third parties as set out below:
Purpose/Activity Type of data
Firebase Analytics
Crash details to diagnose crashes
Determine the user base location
Determine the most used operating system and devices types to enable us to test better
  • A total number of times that users crash in a particular version
  • List of countries and region
  • Device model and OS version

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email if we have your consent or where we have previously given you an opportunity to object to the provision of direct marketing by email in the course of a sale or negotiations for sale of service with you and you have not objected. Where the latter occurs, we will only send you marketing communications about the same or similar products and Services which we feel may be of interest to you. You have the right to withdraw consent and/or indicate you no longer wish to receive marketing communications from us at any time by contacting us.

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

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To install the App and register you as a new User on the App. (a) Identity
(b) Contact
(c) Technical
(d) Profile		 (a) Your consents
(b) Performance of a contract with you.
(c) Necessary for our legitimate interest.
To process and manage in-App purchases in respect to the Services. (a) Identity
(b) Contact
(c) Financial		 (a) Your consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to recover debts due to us)
Storing and using data to improve our data models and algorithms. (a) Technical Necessary for our legitimate interests (to train and improve the accuracy of our data models and analytics and to improve our Service).
To administer and protect our business and our software including troubleshooting, data analysis and system testing. (a) Identity
(b) Contact
(c) Usage
(d) Technical		 Necessary for our legitimate interests (for running our business, provision of administration, IT services and network security).
To monitor trends so we can improve Services. (a) Identity
(b) Contact
(c) Profile
(d) Usage		 (a) Your consent.
(b) Necessary for our legitimate interests (to develop our Services, define types of customers for our products and Services, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you. (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications		 (a) Necessary for our legitimate interests (to develop our products/services and grow our business).
(b) Your consent.
To make suggestions and recommendations to you about goods or services that may be of interest to you. (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications		 (a) Necessary for our legitimate interests (to develop our products/services and grow our business).
(b) Your consent.

CHANGE OF PURPOSE

We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the Purposes set out in the table above.

  • External Third Parties as set out in the Glossary below.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the UK.

7. DATA SECURITY

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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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 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.

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 or other requirements.

In the event that you do not use the App for a period of two years then we will treat the account as expired and your personal data may be deleted.

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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. 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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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. If you withdraw your consent, we may not be able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could 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.

10. GLOSSARY

App means the FOBBS application which allows Users to access educational, vocational, and inspirational content which showcases Black British figures and their achievements.

Services means the specific proprietary software-as-a-service product(s) of ours specified in an order form, including any related documentation, and excluding any third-party products.

User means you and/or the named users authorised by you to use the Services in accordance with the terms of our App.

LAWFUL BASIS

Consent means that you have given us permission (your consent) to process your personal data for one or more specific purposes.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

The names of external third parties may vary from time to time. In the event the categories of external third parties change we will update this privacy policy accordingly to reflect such changes. For further information on external third parties please contact FOBBS directly at hello@fobbs.uk

  • Third party data analytics providers
  • Third party marketing software services providers