PLEASE READ THESE TERMS CAREFULLY BEFORE USING OUR APP
LAST UPDATED AT: 15 Oct 2020
BA Trade Technologies (“we”, “our” and “us”) is committed to protect the personal data of its users (“user”, “you”, “your”) and to respect their privacy. We comply with all relevant data protection laws, including the EU General Data Protection Regulation 2016/679 (GDPR).
BA Trade Technologies, the company owning and operating the App and Site, is your data controller. This means that we are responsible for, and control the collecting and processing of, your personal data. You can find all our details under How to contact us.
In order to download and use our App, we do not require any personal information from you.
There are a few situations in which we do collect some personal information from you, both directly and indirectly. These situations are set out in more detail below.
We welcome any questions, queries and feedback via our e-mail address. During our interaction with you, we may collect some personal information from you or you may provide us with personal information, such as your name and your e-mail address. We use such personal information for the purpose of helping you solve problems, answering your queries or process feedback. We also use your e-mail address to keep you up to date of any changes to this Policy.
We rely on our legitimate interest to answer your queries, improve our App and keep you up to date of changes to this Policy when we process the personal information we collected from you.
By leaving your e-mail address on the form provided on our Site, you can sign up for our newsletter. Obviously, we need your e-mail address to be able to send you our newsletter. We rely on your consent in order to use your e-mail address to send you marketing materials. If you have provided us your e-mail address while communicating with us, we will not use it automatically to send you newsletters without your specific consent to do so. You can always withdraw your consent by contacting us or by clicking on the ‘unsubscribe’ link in the e-mail sent out to you.
Each time you use our App and Site, we collect some information — which may include personal information — from you automatically using third party-technologies such as Google Analytics and Hotjar. Such information includes your Internet Protocol (IP) address used to connect your computer to the Internet, and may also include other technical information. Examples of such information are screen resolution, browser type and version, language, time of your visit, crash/error details, referring site details, clicks on links, operating system type and version and App version.
You can choose to turn off our collection of the above information in the settings of the App.
We rely on our legitimate interest to administer and improve our App — including troubleshooting, data analysis, testing, research, statistical and survey purposes — and our legitimate interest to keep our App safe and secure, when collecting and processing this information.
A cookie is a small text file which is placed onto your computer when you visit our Site.
We use Google Analytics in order to analyze user activity on our Site. Google Analytics leaves a cookie on your computer every time you visit our Site. If you want to know which data Google Analytics collects and processes, please have a look at the information provided via the following link: https://policies.google.com/technologies/partner-sites.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link: https://www.hotjar.com/legal/compliance/opt-out.
Please note that we do not sell your personal information to third parties.
We do share some personal information with selected third parties supplying us with certain services. For example, we use Mailchimp to send out our newsletter. If we share any personal information with such third parties, we require them to take reasonable steps to safeguard any personal data shared with them. We have entered into data processing agreements with all such third-parties.
We also share information with a third-party advertising company that provides our users with advertisements, but we do not share any information about identifiable individuals with them. Such third parties only receive aggregated and/or anonymized information. For example, when you install our App, some technical information such as your operating system type and version will be send to the advertiser in order to allow the advertiser to choose which advertisement to show to you. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
We may also share the personal information we hold about you:
if another company acquires all or part of our assets;
if we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or investigation;
In the event we receive a legal request to disclose your personal information, we may notify you of such request before we do so, unless this is expressly prohibited by the authority making the request or if notifying you would be detrimental to us, the party requesting your personal information, or any other person affected, or to the investigation itself. If we can’t notify you of such requests beforehand for the reasons set out before, we will try to notify you afterwards.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We use encryption to safeguard your personal data. All personal information we collect or receive from you is stored on our secure servers.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized access and data breaches.
If a data breach is detected or suspected, we may suspend our App and Site without prior notice. Should you have reason to believe that your personal information is not secure with us, please notify us as soon as possible.
We only retain your personal data for as long as we need it to fulfil the purposes for which we have initially collected it. We may retain certain information for a longer period of time to comply with applicable laws or in our legitimate interests to prevent fraud and to enhance safety.
Our services are directed to users located all over the world. The personal information we receive and collect from users located in the European Economic Area (EEA) may be transferred to, and stored at, a destination outside the EEA.
Any non-EEA countries may not have the same data protection laws as the EEA. In the event your personal information is transferred to such countries, we have ensured that appropriate safeguards are put in place to protect your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. This may include the use of standard contract clauses approved by the European Commission, binding the parties incorporating those clauses in their contracts to protect the security and privacy of your personal data.
Under data protection laws, you have the following rights, which you can exercise free of charge. You can exercise some of these rights via the settings in the App. Others may require you to contact us. We may request you for proof of identity and address when you exercise your rights to ensure that you are the person entitled to that information. Your rights are:
Access to your personal information and to certain other supplementary information that this Policy is already designed to address.
Require us to correct any mistakes in your personal information which we hold.
Require the erasure of personal information concerning you in certain situations.
Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
Object at any time to processing of personal information concerning you for direct marketing.
Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you. Object in certain other situations to our continued processing of your personal information.
Otherwise restrict our processing of your personal information in certain circumstances.
If you encounter any problems in relation to the use of your personal data, please contact us so we can try to resolve your issue or concern.
As an EU/EEA citizen, you also have the right to lodge a complaint with the supervisory authority in the EU/EEA member state where you work, normally live or where any alleged infringement of data protection has occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or via telephone at 0303 123 1113.
Any changes we make from time to time to this Policy will be acknowledged in our App and on our Site. If the changes are materially affecting you, the changes will come into effect 30 days after we published our notification. Your continued use of our App will be deemed your acceptance of our revised Policy.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to firstname.lastname@example.org or to BA Trade Technologies at 61 Amhurst Road, E8 1LL, United Kingdom.