Introduction
 

This privacy notice aims to inform you about how we collect and process any information that we collect from you from your use of the "Perfect Picks" mobile application ("Mobile Application" or "Service") and any of its related products and services including the website https://www.perfectpicks.com (collectively, "Services"), or that you provide to Grand Slam Digital Ltd ("Grand Slam Digital Ltd", "we", "us" or "our"). Our registered United Kingdom company number is 12650596.

It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.
 

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
 

Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website or any application.

 

1. Data Protection Officer
 

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Mathew Allen at info@perfectpicks.com.
 

2. Data we process
 

We may collect, use, store and transfer different kinds of personal data about you.

Your identity includes information such as first name, last name, title, date of birth.

Your contact information includes information such as your email address and any other information you have given to us for the purpose of communication or meeting.
 

Technical data includes your internet protocol (IP) address, 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 this website.
 

Your profile includes information such as your username and password, preferences, feedback and survey responses.
 

Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.
 

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. For example, we may aggregate profile data to assess interest in a product or service.
 

However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.
 

3. Special personal information
 

Special personal information is data 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. We do not collect any special personal information about you.

4. If you do not provide personal information we need
 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
 

The basis on which we process information about you
 

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
 

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
 

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
 

5. Information we process because we have a contractual obligation with you
 

When you register a Perfect Picks account, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

• verify your identity for security purposes;

• provide you with our services;

• provide you with suggestions and advice on services and how to obtain the most from using one of our websites or apps.
   

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

 

6. Information we process with your consent
 

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, our products and services, you provide your consent to us to process information that may be personal information. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us at info@perfectpicks.com. However, if you do so, you may not be able to use our websites or apps or our services further.
 

7. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so. Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means;

• whether processing (or not processing) might cause you harm;

• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so;

For example, we may process your data on this basis for the purposes of:

• record-keeping for the proper and necessary administration of our business;

• responding to unsolicited communication from you to which we believe you would expect a response;

• protecting and asserting the legal rights of any party;

• insuring against or obtaining professional advice that is required to manage business risk;

• protecting your interests where we believe we have a duty to do so.
   

8. Information we process because we have a legal obligation
 

Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.

Specific uses of information you provide to us

9. Communicating with us
 

When you contact us we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you.

 

10. Complaining
 

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

 

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

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Use of information we collect through automated systems when you visit our website

 

11. Cookies
 

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our websites.

We use cookies in the following ways:

• to track how you use our websites

• to record whether you have seen specific messages we display on our websites

• to keep you signed in to our website

• to record your answers to surveys and questionnaires on our site while you complete them
   

12. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.                 

Disclosure and sharing of your information
 

13. Information we obtain from third parties
 

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use. No such information is personally identifiable to you.

 

14. Third party advertising on our website
 

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
 

Control over your own information
 

15. Your duty to inform us of changes
 

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

 

16. Access to your personal information
 

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account.

 

17. Removal of your information
 

If you wish us to remove personally identifiable information you should contact us to make your request. This may limit the service we can provide to you.
 

18. Verification of your information
 

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
 

Other matters
 

19. Retention period for personal data
 

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;

• to comply with other law, including for the period demanded by our tax authorities;

• to support a claim or defence in court.   
   

20. Compliance with the law
 

Our privacy notice has been compiled so as to comply with the law of each country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our services.

 

21. Review of this privacy notice
 

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our services. We advise you to print a copy for your records. If you have any question regarding our privacy policy, please contact us.