WHO WE ARE

For the purposes of this privacy (" Policy"), " we", " us" and " our" shall mean Apart of Me, a restricted fund under auspices of Prism the Gift Fund, a company limited by guarantee incorporated in England (registered number: 04677253) with its registered address at 20 Gloucester Place, London, W1U 8HA and a registered charity in England and Wales (charity number: 1099682)and its related affiliates and its or their partners, members, directors, officers and employees, as the context required.

This Policy aims to give you information on how we collect and process your personal data through your use of this mobile application (" App") and the game available on it, including any data you may provide when using our App.

PERSONAL DATA WE COLLECT

Personal data means any information about a person that can identify him or her. We collect or receive information in two ways: (1) you voluntarily provide information to us, such as by creating an account on our App, or (2) we collect information automatically through tracking technologies that monitor your use of our App. Each of these methods is described in more detail below.

Information you voluntarily provide

You might provide information to us in connection with your use of our App, such as when creating an account or when you contact us for technical support or any other reason.

The information you provide to us may include your name, your display name and your email address(es). Sometimes we ask for your age and your gender. You may also choose to provide us with the name(s) of the loved one(s) you have lost and information about how he or she died.

Internet protocol addresses (which are unique numbers that link to your online activity) are considered "personal data" in the United Kingdom and will be treated in accordance with this Policy.

If you store information locally on your device, we will not have access to your information (other than usage data and statistics about how you use our App, as described in the next section below).

Information we collect when you use our App

When using our App, we will collect certain information automatically through tracking technologies. This information will include:

  • usage data and statistics about how you use our App, such as the types of content you view or engage with, the features you use, the actions you take, the time, frequency and duration of your activities and any emotions you record as you play;
  • crash reports, which may be automatically generated when our App crashes;
  • information to facilitate a safer and more personalized experience, including your display name or other user identification, your saved preferences, game progress, and device identifiers or usage information for authentication and to prevent against identity theft; and
  • the location of your device, to the extent you may this available to us.

We typically aggregate the data that we collect automatically and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals. However, if any of this information does identify you as an individual, we will treat that information as personal data.

To learn more about out tracking technologies and for our detailed notice, please see Tracking Technologies section below

HOW WE USE PERSONAL DATA

We use the personal data we have only in accordance with the law in the following ways:

Purpose Lawful Grounds
Delivering and supporting our App, including to deliver personalise features and content. To perform our contract with you (our contact is the Terms of Use you accepted when you downloaded our App).
Modifying or improving features, addressing technical issues, preventing identity theft or misuse of our App, and conducting data analytics To perform our contract with you.For our legitimate interests (to improve our App, provide IT services, prevent identity theft and inform our marketing strategy).
Assessing the effectiveness of our App and understand how people interact with the game For our legitimate interests (to improve our App).
Managing our relationship with you and communicating with you about our App, and letting you know about our policies and terms. We also use your information to respond to you when you contact us. To perform our contract with you.
If you have consented to your information being used for such purposes, conducting and supporting research and innovation on child bereavement therapies and counselling. For our legitimate interests and those of professionals involved in bereavement research and therapies (to support, develop and improve research, innovation and counselling in bereavement services and therapies).

Any personal data you provide that has special protections, such as information about your health and wellbeing, will not be used by us except with your explicit consent.

If you have created an account with us, your personal data will be stored on servers in the United Kingdom.

SHARING YOUR PERSONAL DATA

In processing your personal data, we may share your personal data in the following ways:

  • to our vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our App is used and providing customer and IT support services;
  • if you have consented, with research partners, psychologists, academics and other professionals involved in bereavement research and therapies to support, develop and improve research, innovation and counselling in bereavement services and therapies;
  • with law enforcement or in response to legal requests if required to do so by law; and
  • if the ownership or control of all or part of our charitable business changes (including assets such as the App), we may transfer your information to the new owner.

DATA SECURITY

We employ security measures to protect your personal data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected.

The transmission of information using Wi-Fi networks and cellular data networks may not be completely secure. Although we will use reasonable endeavours to protect your personal data, we cannot guarantee the security of data transmitted to us using our App and any such transmission is made at your own risk.

DATA RETENTION

We will keep your personal data for as long as you have an account with us, while we have a legitimate business need to do so, or as required by law, whichever is the longer.

To determine our appropriate retention period for your personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and our legal obligations.

CHILDREN

Due to the nature of our activities and the purpose of our App, we hold personal data relating to children and young people when they access our App. These details are held with the explicit consent of the child (if the child is 13 years or older), or the child's parent or guardian (if the child is under 13 years). We ensure this data is appropriately protected by us and any third party we disclose it to.

We do not collect any information from children that is not required for them to use the App. Parents or guardians can contact us to:

  • request copies of the personal data we collected about their child;
  • direct us to delete the personal data we collected about their child;
  • direct us to stop collecting or using personal data regarding their child; and
  • prohibit the disclosure of personal data regarding their child to third parties not needed to provide the App.

Unity Analytics may collect personal data from children while helping us analyze use of the App. Please contact us with questions about Unity Analytics’ data practices.

TRACKING TECHNOLOGIES

We use tracking technologies, such a device fingerprinting, in connection with the operation of our App for analytics purposes. These help us better understand the behavior of the users on our App and improve our App accordingly, for example by making sure users are finding what they need easily. By choosing to use our App after having been notified of our use of tracking technologies in the ways described in this Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Please note that you may not be able to control tracking technologies through settings on your mobile device.

YOUR RIGHTS

Subject to applicable law, you have the following rights in relation to your personal data:

  • Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your personal data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or 'block' the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
  • Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your personal data, and we will do so, if we are relying on a legitimate interest to process your personal data - unless we demonstrate compelling legitimate grounds for the processing.
  • Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
  • Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to UK Information Commissioner's Office (" ICO"). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

You may exercise your rights by contacting us as indicated under the How to Contact Us section below.

THIRD-PARTY LINKS

This App 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 policies. We encourage you to read the privacy policy of each website you visit.

CHANGES TO THIS POLICY

We may amend this Policy from time to time by uploading a replacement Policy to our App. To ensure that you are always aware of how we use your personal data we will update this Privacy Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements.

By continuing to use our App or providing us with information following such a replacement Policy being uploaded, you agree that you will be deemed to have agreed to be bound by the replacement Policy.

HOW TO CONTACT US

If you have any questions about this Policy or our data processing practices, you can contact us by:

  • Writing to us at: Apart of Me, 20 Gloucester Place, Marylebone, London W1U 8HA
  • Emailing us at: [email protected]