Privacy Policy

Updated 26th July 2018

Background

RJM Digital Platforms understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website and downloads our mobile application, https://www.thehappyhoursapp.com , (“Our Site”) and “The Happy Hours App” (“Mobile Application”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and Mobile Application. If you do not accept and agree with this Privacy Policy, you must stop using Our Site and Mobile Application immediately.

1. Information About Us

Our Site and Mobile Application is owned and operated by RJM Digital Platforms.

2. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site and Mobile Application. Our Site and Mobile Application 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.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

3.1 Persons under the age of 18

Our Site and Mobile Application are not intended for persons under the age of 18, we do not knowingly collect data relating to these persons. Our Site and Mobile Application are not intended for use by persons under 18 years of age. If you are under 18, do not use or provide any information on Our Site or Mobile Application, or on or through any of their features register on Our Site or Mobile Application, make any purchases through Our Site or Mobile Application, use any of the interactive or public comment features of Our Site or Mobile Application or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username. If we learn we have collected or received personal information from a person under 18 we will delete that information. If you believe we might have any information from or about a person under 18 please email info@rjm.digital.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 12.

2. The right to access the personal data we hold about you. Part 11 will tell you how to do this.

3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.

4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 12 to find out more.

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

6. The right to object to us using your personal data for a particular purpose or purposes.

7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.

5. What Data Do We Collect?

Depending upon your use of Our Site and Mobile Application, we may collect some or all of the following personal:

  • Name;
  • Date of birth;
  • Name;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • Information about your preferences and interests;
  • 6. How Do You Use My Personal Data?

    Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data, or because it is in Our legitimate business interests to use it. Your personal data may be used for the following purposes:

  • Supplying services to you. Your personal details are required in order for us to enter into a contract with you.
  • Personalising and tailoring services for you.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time.

  • With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message with information, news, and offers on Our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

    7. How Long Will You Keep My Personal Data?

    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

    8. How and Where Do You Store or Transfer My Personal Data?

    We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be under the GDPR as follows.

    We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, Our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”.

    Please contact us using the details below in Part 12 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

    9. Do You Share My Personal Data?

    We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

    10. Can I Withhold Information?

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

    11. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email shown in Part 12.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

    We will respond to your subject access request within 1 month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

    12. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

    Email address: info@rjm.digital

    13. Changes to this Privacy Policy

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

    Any changes will be immediately posted on Our Site and Mobile Application and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site and Mobile Application following the alterations. We recommend that you check this page regularly to keep up-to-date.