Updated 16th October 2020
We are committed to protecting your Information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you use the Platform, you trust us with your information. We take your privacy very seriously. We want to explain in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the Platform.
CHANGES TO THE POLICY OR YOUR PERSONAL DATA
We review the Policy regularly and it is your responsibility to check regularly and determinate whether this Policy has changed. If you do not agree to any change to the Policy then you must immediately stop using the Platform. In the event we make any significant changes to the Policy we will use our best endeavours to inform you or such changes in advance in writing.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes for example you change your email address.
The Platform is owned and operated by Howbout Ltd (trading as Howbout), a company registered in England and Wales with company number 11962821 whose registered office is situated at Wework Senna Building, Gorsuch Place, London, England, E2 8JF (Howbout/we/us/our). Howbout is the controller (also known as a data controller) and is responsible for your personal data. The term “you” refers to the user wishing to access and/or use the Platform.
Howbout is a social planning and calendar management app. Users who register an account (a Registered User) can organise, respond to and chat on a Plan or Reminder (Howbout Events) with other Registered Users.
Registered Users can send and receive friend requests to and from other Registered Users and invite other Registered Users to Howbout Events through the Platform. They can also send friend requests and invite a non-Howbout user (an External Individual) to Howbout Events through a link via other communication platforms, for example, by SMS text message.
When two Registered Users become Howbout Friends, they have the option to share their Howbout calendar (Calendar), very limited Howbout calendar information (Availability) or decide not to share any calendar information with each other. When sharing their Calendar or Availability, Registered Users can also choose to include any or all third party calendars they have chosen to integrate with their Howbout calendar. Please be aware you have full control over whether you share your Availability, Calendar or neither of these with your Howbout friends.
INFORMATION WE MAY COLLECT ABOUT YOU
Personal information you disclose to us
In Short: We collect personal information that you provide to us including information such as your name and email address, and information about your contacts and calendar data.
We collect personal information that you voluntarily provide to us when registering and using the Platform, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the products and features you use. When you use the Platform and/or when you otherwise deal with us, we may collect the following information about you (the Information):
- personal information including your first and last name and a photograph;
- contact information including your email address and phone number;
- if you sign up to the Platform through a third-party account or social networking service (such as Facebook, Apple or Google, each a Social Login, we may extract information from your applicable Social Login account (for example your name, email address, photograph, event and activity information and other personal information that your privacy settings on the Social Login account may permit us to access);
- information about your connections and contacts when you connect with other Registered Users or External Individuals or invite them to attend the events which you organise through the Platform;
- location information (if you give us your explicit consent), including your geolocation (latitude and longitude) which we can collect through various means (depending on your device and service), such as GPS and WiFi.
- information about your contacts which you already had in your phone contact directory (if you give us your explicit consent);
- calendar and event information held with third-party providers such as Google calendar, Microsoft Outlook calendar and Apple calendar (if you give us your explicit consent);
- photo, video, documents and other digital media information which you upload from your phone’s gallery (if you give us your explicit consent) or take and upload with your phone’s camera (if you give us your explicit consent)
- information obtained through our correspondence and monitoring; and
- other information relevant to services, customer surveys and/or offers.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit the Platform.
We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Platform and other technical information. This information is primarily needed to maintain the security and operation of the Platform, and for our internal analytics and reporting purposes.
Occasionally we may receive information about you from other sources, for example from other users of the Platform who provide your contact details to us when creating or managing their events through the Platform. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
How do we use your information?
In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the Platform for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Obligations). We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process your Information for the following purposes:
- to operate, administer, maintain, provide, analyse and improve the Platform and the services available through the Platform;
- to investigate and address any comments, queries or complaints made by you regarding the Platform, and any similar or related comments, queries or complaints from other users;
- to ensure that content on the Platform is presented in the most effective manner for you and for your device;
- to conduct research, statistical analysis and behavioural analysis (including anonymising data for these purposes) and to provide insights based on aggregated, anonymous data collected through the research and analysis;
- to allow you to participate in interactive features on the Platform, including inputting information and providing feedback;
- to contact you for marketing purposes;
- to disclose your Information to selected third parties as permitted by this policy;
- to notify you about changes to the Platform; and
- to comply with our Legal Obligations, including obligations relating to the protection of your Information.
Will your information be shared with anyone?
In Short: We only share information to comply with Legal Obligations, to protect your rights, fulfil our business obligations to you or with your Consent.
We only share and disclose your Information in the following situations:
- Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
- Third-Party Service Providers. We may share your Information with third-party vendors, service providers, contractors or agents who perform services and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. They will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
- Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
- With your Consent. We may disclose your Information for any other purpose with your Consent.
- Other Registered Users. We’ll disclose your first name, last name and photograph to other Registered Users you become friends with. By default, we’ll share your Availability with each of your Howbout friends. This means that your Howbout friends will simply be able to see if you’re “free”, “busy” or “might be busy” when they’re organising a Plan with you – they can’t see any details about your calendar events. You may choose to instead share your Calendar with any or all of your Howbout friends – which allows them to have a read-only view of your calendar (and any other external calendars you choose to share), except for any Howbout events you mark as “secret”). You also have the option to share neither your Availability nor your Calendar with any or all of your Howbout friends.
We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Platform. In such circumstances we do not disclose any information which can identify you personally.
Is your information transferred internationally?
In Short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.
Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law. To the extent that any transfer requires approved safeguards are in place (for example if transferring outside of the European Economic Area that the EU model contract clauses or if to the USA that the entity it is transferred to is EU/US Privacy Shield registered) we will ensure these measures are in place.
In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the Platform.
The Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Platform. You should review the policies of such third parties and contact them directly to respond to your questions.
How long do we keep your information?
In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing Business Purpose to process your Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
How do we keep your information safe?
In Short: We aim to protect your Information through a system of organisational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of personal information to and from the Platform is at your own risk. You should only access our services within a secure environment.
Do we collect information from minors?
In Short: We take steps to ensure that the Platform are only used by those over 12 years of age and we do not knowingly collect data from or market to children under 12 years of age.
We do not knowingly solicit data from or market to children under 12 years of age. By using the Platform, you represent that you are at least 12 years of age. If we learn that personal information from users less than 12 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 12, please contact us at email@example.com.
Your Consent to processing
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Platform.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing firstname.lastname@example.org.
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Platform and you object or do not provide Consent to us processing your Information, the Platform will not be available to you.
Marketing and opting out
If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to email@example.com or unsubscribing from the communications.
You may at any time review or change the information in your account. You may change your account name or email address on your account tab in the Howbout App.
If you wish to terminate your account you must click on the “Delete Account” button on your account tab in the Howbout App. Some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service and/or comply with legal requirements.
What are your privacy rights?
In Short: You have certain rights in respect of your Information.
You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Information, (ii) to request rectification or erasure of your Information; (iii) to restrict the processing of your Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Information. To make any requests, please contact us at firstname.lastname@example.org. We will consider and act upon any request in accordance with applicable data protection laws.
We may need to request specific information from you to help confirm your identity and ensure your right to access your Information (or to exercise any of your other rights). This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further information in relation to your request to speed up your response.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.
We welcome your feedback and questions on this Policy. If you wish to contact us please email us at email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.