Privacy Policy

Whereverly Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website or use our apps or services. It will also tell you about your privacy rights and how the law protects you.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Important information and who we are

We are Whereverly Limited. We are a company incorporated and registered in Scotland. Our company number is SC542009. Our registered office address is 2 Walker Street, Edinburgh, EH3 7LB.

When we refer to “we”, “us” or ”our” in this policy, we are referring to Whereverly Limited. We are the data ‘controller’ in relation to the personal data you provide to us, which means we determine the purposes and the way in which your personal data is, or will be, processed.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal so that you can be confident when you interact with us that you know what your personal data is being used for and that it is being kept safe. This covers the personal data we obtain in relation to our websites at https://whereverly.com and https://learntolovedigital.com ( “Sites”), through the mobile apps we develop for our customers ( “Apps”) and in relation to the data services we provide our customers in relation to the use of the Apps ( “Services”).

It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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 the other notices and is not intended to override them.

We use the following definitions in this policy to cover the different categories of individuals that this policy applies to:

Customer: means the tourist organisation, local authority, charity of other third party for whom we develop an App and provide our Services;
Device: is the mobile device onto which an App is downloaded;
End User: means the individual who has downloaded, and uses, an App on a Device
Registered User: means an individual employee, contractor or agent of a Client who is authorised to register to use the Services by that Client; and
User: means any person accessing our Sites.

Third-party links

Our Sites 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 our Sites, we encourage you to read the privacy notice of every website you visit.

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 personal data by filling in forms or by corresponding with us in person, by email, by phone, by post or otherwise. This includes personal data you provide when creating an account with us and when you request marketing communications to be sent to you.
Automated technologies or interactions. As you interact with our Sites and/or use our Apps and/or Services we may automatically collect Technical Data about your equipment, Device, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below on Cookies for further information.
Third parties or publicly available sources We may receive personal data about you from various third parties and public sources. For example, analytics providers such as Google.

Information we collect from you

We may collect and process the following data about you:

Account Data: is the information provided if you are an End User or Registered User in order to register for and use the App or Services. The information you give us may include your name, address, e-mail address and phone number, the Device's phone number, username, password and other registration information.
Contact Data: is the information you provide us with when forms on our Sites are completed including name, last name, name, email address and company.
Device Data: this is the technical information we automatically collect from your Device when you use the App including the type of Device, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and time zone setting.
Location Data: this is the GPS technology information we use to determine your current location if you are an End User. Some features of our Apps require this personal data for the feature to work. You can turn off this functionality at any time by turning off the location services settings for the Apps on the Device but doing so will not enable you to use the Apps properly for these features.
Marketing Data: If you consent to receiving updates about our Apps and Services, new products and other changes we may use your name and email address to send you such updates by email.
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 the Sites.
Usage Data: means information about how your use of the Sites, Apps and Services.

How do we use your personal data?

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

Where we need to perform the contract for services we are about to enter into or have entered into with you (i.e. when you purchase something from us).
Where we have your prior consent to use your personal data (for example, where you have consented to receiving marketing).
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. 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.
Where we need to comply with a legal or regulatory obligation.

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.

Please 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
To respond to your enquiries	Contact Data	Consent (as you are requesting us to respond to you)
		Necessary for our legitimate interests (to respond to enquiries from Customers and potential customers
To enable Registered Users to access the Services	Account Data	Performance of a contract with you
To enable End Users to use the App	Account Data Location Data	Performance of a contract with you
To send you marketing emails	Marketing Data	Consent Legitimate interests (to market to network of Customers and contacts)
To personalise our Sites and improve user experience in relation to the Sites, the Apps and Services	Device Data Technical Data Usage Data Location Data	Legitimate interests (to improve customer interactions)
To administer and protect our business and the Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Contact Data Contact Data Technical Data	Necessary for our legitimate interests (for running our business, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Performance of a contract with you
To analyse and create anonymised data on End User use and interaction which we may share with Customers	Device Data Usage Data Location Data	Necessary for our legitimate interests (to understand and improve End User interaction, to develop analytical data for Customer use)

Disclosure of your information

We may have to share your personal information with the following third parties:

External third-party service providers acting as processors who provide the following services:
- Web hosting;
- Metrics and analytics; and
- Marketing, mailing and survey third party tool providers
Please note this includes the international service providers listed below in International transfers.
Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors, controllers or joint controllers who require reporting of processing activities in certain circumstances. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets
If Whereverly Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

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.

International transfers

If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
If we use certain service providers based outside of the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
If we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
In any other case, we will obtain your explicit consent before any transfer takes place.

Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. The table below sets out details of transfers to such third parties and the relevant safeguards.

Service provider	Description of service	Safeguards
Google Forms	Customer feedback and survey	Privacy Shield
EventBrite	Marketing- event management	Privacy Shield

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures in accordance with industry best practice 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.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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

How long we store your personal data for

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements

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 requirements.

We normally delete personal identifiable information we hold on you within 10 years but in some circumstances you can ask us to delete your data sooner: see Deleting personal data below for further information.

Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, then we may use this information indefinitely without further notice to you.

Cookies
What are cookies?

A cookie is a text file containing a small amount of information that is sent to your browser when you visit a website. The cookie is then sent back to the originating website on each subsequent visit, or to another website that recognises it. Cookies are an extremely useful technology and do lots of different jobs.

We may collect information through the use of cookies, web beacons or similar analytics-driven technologies.

What cookies do we use?

The cookies that we use fall into the following categories:

Strictly necessary cookies. These are cookies that are required for the operation of our Sites. They include, for example, cookies that enable you to log into secure areas of our Sites.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using it. This helps us to improve the way our Sites works, for example, by ensuring that Users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Sites. This enables us to personalise our content for you, greet you by name and remember your preferences.. They allow us to recognise and count the number of visitors and to see how visitors move around our Sites when they are using it. This helps us to improve the way our Sites works, for example, by ensuring that Users are finding what they are looking for easily.
Targeting cookies. These cookies record your visit to our Sites, the pages you have visited and the links you have followed. We will use this information to make our Sites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We use various types of cookies (including some that we place and others which we permit third parties to place on our Sites) for a number of purposes. The information collected by cookies allows us to monitor how many people are using our services and their interactions with other services. Cookies are also used to facilitate a user's log-in, as navigation aids, and as session timers.

We also use cookies to match information to third-party databases to create marketing profiles that could result in you seeing customised advertising or content when browsing the internet. We do not link non-personal information from cookies to personally identifiable information without permission.

If for any reason you do not want us to track your use of our Sites using cookies, you can opt out of this using your browser settings and can also select the option “Do Not Track” (for more information please refer to your browser).

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

To find out how to manage cookies on popular browsers:

To opt out of being tracked by Google Analytics across our Sites, visit http://tools.google.com/dlpage/gaoptout.

We use web beacons to collect information about the use of our services. The information collected by web beacons allows us to monitor how many people are using our services, how many people open our e-mails, and determine for what purposes these actions are being taken. Our web beacons are not used to track activity outside of our services.

Before cookies are placed on your computer or device, you will receive a pop-up prompt requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our Sites may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Type	Purpose	More Information
Google Analytics	3rd Party	Analytics	https://support.google.com/analytics/answer/6004245
Add This	3rd Party	Social Sharing	http://www.addthis.com/privacy

Your rights

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

If you wish to exercise any of the rights set out below, please Contact us. 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 may refuse to comply with your request in these circumstances.

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

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.

Access to your information

You have the right to ask for a copy of the information which we hold on you (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.

Correcting personal data

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

Deleting personal data

You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. This is more commonly known as the ‘right to be forgotten’. 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 informat or where we are required to erase your personal data to comply with local law.

Please note, however, that we may not always be able to comply with your request to delete or remove personal data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Objecting to processing

You have the right to stop us processing your personal data for direct marketing purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at contact@whereverly.com.

You may also object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restriction of processing

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; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transferring your personal data

In certain circumstances, you may 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.

Please 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.

Withdrawing consent

Where we are relying on consent to process your personal data you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Review by an independent authority

You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office. If you do have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO, so please do Contact us in the first instance if possible.

Changes to our privacy policy

This version was last updated on 22nd June 2018

Historic version of this policy can be obtained by Contacting us.

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.

Questions, comments and requests regarding this policy are welcomed and should be addressed to our Data Privacy Manager at contact@whereverly.com.