Citizen Mobile App - Privacy Policy

Last Updated - November 2020

This privacy policy applies between you, the User of this Mobile App and Cloud 9 Technologies Ltd, the developer of this Mobile App. Cloud 9 Technologies Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Mobile App.

Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

   This privacy policy applies only to the actions of Cloud 9 Technologies Ltd and Users with respect to this Mobile App. It does not extend to any websites or other mobile apps that can be accessed from this Mobile App including, but not limited to, any links we may provide to social media websites.

   Data	collectively all information that you submit to Cloud 9 Technologies Ltd via the Mobile App. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
   Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
   GDPR	the General Data Protection Regulation (EU) 2016/679;
   Cloud 9 Technologies Ltd, we or us	Cloud 9 Technologies Ltd, a company incorporated in England and Wales with registered number 07255288;
   User or you	any third party that accesses the Mobile App and is not either (i) employed by Cloud 9 Technologies Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Cloud 9 Technologies Ltd and accessing the Mobile App in connection with the provision of such services;
   Mobile App	the mobile application which Cloud 9 Technologies have developed on behalf of the local authority

2. In this privacy policy, unless the context requires a different interpretation:

   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. "including" is understood to mean "including without limitation";
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Cloud 9 Technologies Ltd and Users with respect to this Mobile App. It does not extend to any websites or other mobile apps that can be accessed from this Mobile App including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Cloud 9 Technologies Ltd is the "data processor". This means that Cloud 9 Technologies Ltd processes the data on behalf of the "data controller" (the local authority).

Data collected

5. We may collect the following Data, which includes personal Data, from you:

   1. name;
   2. address;
   3. contact information such as email addresses and telephone number;
   4. location information;
   5. unique device token (used to send push notifications);
   6. operating system version, device manufacturer, model and system information (opt-in);
      in each case, in accordance with this privacy policy

How we collect Data

6. We collect Data in the following ways:

   1. data is given to us by you; and
   2. data is collected automatically.

Data that is given to us by you

7. Cloud 9 Technologies Ltd will collect your Data in a number of ways, for example

   1. when you report issues to the local authority using the "Report-It" forms;
   2. when you sign up for push notifications;
   3. when you use our services;
      in each case, in accordance with this privacy policy.

Data that is collected automatically

8. To the extent that you access the Mobile App, we will collect your Data automatically, for example:

   1. we automatically collect some information about your usage of the Mobile App. This information helps us to make improvements to Mobile App content and navigation, and includes the date, times and frequency with which you access the Mobile App and the way you use and interact with its content.

Our use of Data

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Mobile App. Specifically, Data may be used by us for the following reasons:

   1. to send push notifications such as automated bin reminders or details of disruptions to council services;
   2. to send information (including contact details, location information and photographs) to the local authority when the "Report-It" forms are submitted;
   3. to provide details about local council information such as local councillors, planning applications, food hygiene inspections or places of interest;
      in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

Who we share Data with

11. We may share your Data with the following groups of people for the following reasons:

    1. relevant local authorities - to fulfil service requests, send notifications and provide information about council services;
       in each case, in accordance with this privacy policy.

Keeping Data secure

12. We will use technical and organisational measures to safeguard your Data, for example:

    1. all data sent to and from our servers is encrypted (using 256-bit encryption).
    2. we store your Data on secure servers.
    3. access to any accounts is controlled by a password and a user name that is unique to you.

13. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this email address: privacy@cloud9technologies.com.

Data retention

14. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

15. Even if we delete your Data, it may persist on backup or archival media for legal or regulatory purposes.

3rd Party Services

16. We may use the following 3rd party services to provide functionality and to enable us to keep improving the app:

    1. Google Analytics (opt in) - to enable collection of anonymous usage information.
    2. Google Firebase - to provide push notification functionality.
    3. Sentry.io (opt in) - to collect information regarding runtime errors and crashes which helps us improve the app.

Your rights

17. You have the following rights in relation to your Data:

    1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase - the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
    5. Right to data portability - the right to request that we move, copy or transfer your Data.
    6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

18. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: privacy@cloud9technologies.com.

19. Even if we delete your Data, it may persist on backup or archival media for legal or regulatory purposes

Links to websites

20. This Mobile App may provide links to 3rd party websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

21. Cloud 9 Technologies Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Cloud 9 Technologies Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

22. We may also disclose Data to a prospective purchaser of our business or any part of it.

23. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

General

24. We may also disclose Data to a prospective purchaser of our business or any part of it.

25. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

26. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

27. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

28. Cloud 9 Technologies Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately updated in the Mobile App and you are deemed to have accepted the terms of the privacy policy on your first use of the Mobile App following the alterations.

    You may contact Cloud 9 Technologies Ltd by email at privacy@cloud9technologies.com.