1.1. GingeLand Limited t/a GingeLand (a company incorporated in Ireland with registered number 654190) ("we", “our” and “us”) is an Irish software development company. Our product “What2Do – The Community Event Guide” (the Mobile App) is an online community event guide and advertising platform for any kind of local/community event.

1.2. We are committed to protecting and respecting your privacy in relation to your use of our website, applications and all other licensed applications operated by us (the “Licensed Applications”).

1.3. We have adopted the following policies to safeguard your personal information and to protect its confidentiality. Please ensure that you read this Privacy Policy before using any Licensed Application.

1.4. If you do not read or if you disagree with any aspect of the Privacy Policy, forum standards and rules, acceptable use policy or terms and conditions, you agree that you will not use any of the Licensed Applications. By accepting our Privacy Policy in registration or installation, you consent to our collection, processing, controlling, storage, use and disclosure of your personal data as described in this Privacy Policy.

1.5. Please be aware that if you access any Licensed Application from a third-party social network site (such as www.facebook.com or www.twitter.com) you may also be required to accept the terms of use and the privacy policy of that third-party site.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

2.1. We collect personal data (or personal information), and non-personal information. The types of information we collect depend on the nature of your interaction with us. You may choose not to provide us with your personal information. However, if you make this choice, we may not be able to provide you with the product, service, or information that you requested.

2.2. Personal data or personal information means data or information about you, as an individual, from which an individual can be identified. We may collect personal data including the following:

2.2.1. Identity data: your first name, last name, title, date of birth or gender;

2.2.2. Contact data: your contact information including your postal address, telephone number and email address;

2.2.3. Profile data: your personal preferences including opinions, interests, hobbies, product wish lists, language preferences;

2.2.4. Marketing data: your preferences in receiving marketing from us and our third parties and your communication preferences;

2.2.5. Transaction and Financial data: your financial information and transaction information including products purchased, method of payment, amount paid, and credit or debit card number;

2.2.6. Location data: your last searched location is stored for home page personalisation and to access again on reopening the app;

2.2.7. Contacts: your contacts will be stored if adding friends to the app;

2.2.8. Photos/Gallery: your photos stored on the device will be stored on creation of entity or event as an administration user; and/or

2.2.9. File Access: your calendar on import or export of calendar to the app.

2.3. Non-personal information does not identify you as an individual. For example, we may collect certain non-personal data when you visit our Licensed Application, such as your Internet Protocol address, your device id, the type and version of browser you are using or the referring URL; or we may collect and summarise customer information in a non-personal, aggregate format for statistical and research purposes. If we combine or connect the non-personal information with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Policy.

2.4. We agree that we will never request, nor should you ever have to provide without your explicit consent, any data which falls under a special category of personal data. The special categories are:

2.4.1. personal data revealing racial or ethnic origin;

2.4.2. political opinions;

2.4.3. religious or philosophical beliefs;

2.4.4. trade union membership;

2.4.5. genetic data and biometric data processed for the purpose of uniquely identifying a natural person;

2.4.6. data concerning health; or

2.4.7. data concerning a natural person’s sex life or sexual orientation.

3. HOW DO WE COLLECT INFORMATION FROM YOU?

3.1. When you register to use a Licensed Application, whether directly or indirectly, we may request you to provide us with some or all of the following information, which we will collect and store:

i. your age or birthday;

ii. your first and last names;

iii. your gender, if applicable;

iv. your e-mail address; and

v. a password and other information that helps us confirm that it is you accessing your account.

3.2. When you use a Licensed Application, whether directly or indirectly, we may collect and store the following information:

a) how you used the Licensed Application;

b) your physical location as you used the Licensed Application;

c) photographs which you have uploaded to the Licensed Application;

d) external calendar events you may have imported into the Licensed Application

e) the device ID associated to the Licensed Application for delivery of push notifications; and

f) such other information as we may deem of use for the purpose of analysing general use patterns of the Licensed Application.

3.3. In respect of processing your physical location, we collect and use your device location information as you use our Licenced Application. Our Licenced Application includes location-based events. The core feature of these events is to provide information on events tied to your real-world location, so we need to know where you are to provide these event details for you. We identify your location using the native services provided by your device (like GPS), in conjunction with a third-party location service that is invoked when you access the Licenced Application.

3.4. From time to time we may supplement information you give us with information, including from the third parties you may use to access the Licensed Application, and from other sources, such as information validating your address or other available information you have provided to us. This is to help us maintain the accuracy of the information we collect and to help us provide better service.

3.5. As you interact with our licensed applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4. HOW DO WE USE YOUR PERSONAL DATA?

4.1. We will only use your personal data when the law allows us to. The primary reason we collect personal data from you is to provide you with a better interactive experience. We will typically use this information primarily for the following purposes:

4.1.1. where we need to perform the contract, we are about to enter into or have entered into with you;

4.1.2. 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; and

4.1.3. where we need to comply with a legal obligation.

4.2. Examples of how we may use your personal data are set out in the table below alongside the types of lawful basis that we will rely on to process your personal data:

Purpose/ Activity	Possible Lawful Basis for Processing
To register you on any Licensed Application	Performance of a contract with you
To allow you use any Licensed Application	Performance of a contract with you
To administer Licensed Application and to resolve technical problems	Performance of a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To customise your experience of using the Licensed Application	Performance of a contract with you
To improve the Licensed Application functionality	Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To provide technical support and respond to user inquiries	Performance of a contract with you Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To prevent fraud or potentially illegal activities	Necessary to comply with our legal obligation
To enforce terms and conditions of use	Necessary to comply with our legal obligation
To notify you of improvements and changes to Licensed Application	Performance of a contract with you
To encourage input and feedback from you to improve our products and services	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To collect fees	Performance of a contract with you
To analyse trends and user traffic and gather statistical information	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Customer service	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer a loyalty program, including but not limited to tracking and analysing your events, purchases and preferences to better understand your product and service needs and eligibility	Performance of a contract with you
To facilitate your acceptance of offers made by our third-party marketing partners	Necessary to comply with our legal obligation
To tailor our online content based on your preferences	Performance of a contract with you
To measure and improve the effectiveness of our Licensed Application or our marketing endeavours	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To offer and promote additional products and services we offer	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

4.3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email, including the optional What2Do newsletter. You have the right to withdraw consent to marketing at any time by contacting us via the My Notifications section of the Mobile App or as indicated below under the heading “Contacting Us”.

5. DO WE SHARE YOUR INFORMATION?

5.1. Opt-In

We do not sell, rent or share your personal data to any third-party except as described in this Privacy Policy. We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes.

5.2. Opt-Out

5.2.1. You can ask us to stop sending you marketing messages at any time. You can exercise your right to prevent such processing by checking certain boxes on the notification preference forms we use to collect your data. You can also exercise the right at any time by contacting us as indicated below under the heading “Contacting Us”.

5.2.2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of a Licensed Application.

5.3. International Transfers

5.3.1. Some of these operations may result in personal data collected by us being stored or processed by staff outside of Ireland or the European Economic Area ("EEA"). Whenever 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:

5.3.1.1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;

5.3.1.2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in European Union.

5.3.2. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5.4. We may use third parties to manage one of more aspects of our business operations, including the processing or handling of personal data. We may share personal data with such third parties to perform services on our behalf such as fulfilling online orders, processing non-cash payments, sending marketing communications, servicing products, conducting research surveys, verifying and validating information that you have provided to us, delivering products, and providing customer support services. When we do use an outside company, we use contractual and other appropriate means to ensure that your personal data is used in a manner that is consistent with this Privacy Policy.

5.5. We have taken precautions to prevent the fraudulent use of your information on our Licensed Application. We have adopted industry standard authentication procedures to ensure your protection while shopping with us online. This includes, but is not limited to, contacting financial institutions or credit reporting agencies to ensure the authenticity of your credit card and to validate your credit card billing information

5.6. We may share personal data gathered on our Licensed Application amongst our corporate parents, subsidiaries, affiliates or divisions for internal business purposes in accordance with this Privacy Policy. If we share your information within its corporate family, we will ensure that your information continues to be used only in accordance with this Privacy Policy and your expressed choices.

5.7. Any information we have about you may be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets. Should such a transfer occur, we will use reasonable efforts to ensure that the transferee uses your information in a manner that is consistent with this Privacy Policy.

5.8. We may disclose your information as permitted or required by law or to comply with any legal process, as well as to protect and defend our rights and/or that of our customers.

6. HOW DO WE PROTECT YOUR INFORMATION?

6.1. The file containing your personal data or information will be stored on our servers and will only be accessible to our employees and those of our agents and service providers who require it in the course of their duties. We take appropriate steps to protect your personal data. We maintain appropriate safeguards and current security standards to protect your personal data against unauthorised access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; electronic data is stored behind secured encryption access; we use technological tools like firewalls and passwords; we only collect information that is adequate and relevant to the service we provide; and we ensure that our employees are trained on the importance of maintaining the security and confidentiality of personal data.

6.2. Although we cannot take responsibility for any theft, misuse, unauthorised disclosure, loss, alteration or destruction of data by a third-party, we take reasonable precautions to prevent such occurrences. 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.

7. YOUR RIGHTS

7.1. Under certain circumstances, by law you have the right to:

7.1.1. request access to your personal data;

7.1.2. request correction of the personal data that we hold about you;

7.1.3. request erasure of your personal data;

7.1.4. object to processing of your personal data;

7.1.5. request the restriction of processing of your personal data; and

7.1.6. request the transfer of your personal data to another party.

7.2. You may take any of the above actions at any time by contacting us as indicated below under the heading “Contacting Us” for data requests.

7.3. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive we reserve the right to charge a reasonable fee, taking into account the administrative costs of providing the information or taking the action requested, or we may refuse to act on your request.

7.4. 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.

7.5. We try to respond to all legitimate requests within one month. Occasionally, it could 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 on the status of your request.

7.6. WITHDRAWAL OF CONSENT

If you no longer consent to our processing of your data (in respect of any matter referred to in this Privacy Policy as requiring your consent), you may request that we cease such processing by contacting us via our contact details as referenced below or via the support section(s) of our Licenced Applications. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the Service to you.

8. WHEN IS YOUR INFORMATION REMOVED?

We keep your information only as long as we need it, for the legitimate purposes we collected it for and to meet any legal requirements. We have retention standards that meet these parameters. We agree with you to destroy your information when it is no longer needed, or we will remove your personally identifiable information to render it anonymous.

9. WHAT ARE COOKIES?

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

10. HOW DO WE USE COOKIES?

10.1. Our Company uses cookies in a range of ways to improve your experience on our website, including:

· Understanding how you use our website

· Submitting online forms

Please see our Cookies Policy here for further information.

10.2. LINKS TO THIRD-PARTY WEBSITES

Our Licensed Applications may contain links that permit you to link to other websites or Internet resources. When you click on one of those links you are connecting to another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal data. We encourage you to read the privacy policies of those other websites before you submit any personal data to them.

11. CHILDREN’S PRIVACY

11.1. We do not knowingly collect or solicit personal data from anyone under the age of 16 in Ireland or under the relevant age threshold in other jurisdictions where the child is located.

11.2. If you are under the relevant age threshold, please do not send any information about yourself to us, including your name, address, telephone number, or email address, without the authorisation of your parents. No one under the age of 16 years (but you must be older than 13 years) may provide any personal data without such authorisation. No one under the age of 13 years is permitted to use the Licensed Application.

11.3. In the event that we learn that we have collected personal data from a child under the age of consent without the authorisation of the holder of the parental responsibility, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of consent without the aforementioned authorisation, please contact us.

12. CONTACTING US

12.1. If you have any questions, concerns or complaints about the privacy practices of our organisation, please contact customer support at info@gingeland.com. We will respond to your request or investigate your concern as quickly as we can, but no later than 40 days from the date of receipt of your query. Similarly, you may raise concerns via the What2Do Support section of our Mobile App.

12.2. If you wish to raise a data request, you can do so by contacting our DPO at data-request@gingeland.com.

12.3. Please remember that email sent over the internet is not secure. If you send an email directly to us from your own email account, the contents will not be encrypted. We strongly recommend that you do not send sensitive information (like a credit card number) to us via unencrypted email. We are not responsible for any transmission by you of any personal data over the Internet.

12.4. You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

13. DISCLAIMER

TO THE EXTENT PERMITTED BY LAW, WE, OUR DIRECTORS, EMPLOYEES, SERVANTS AND AGENTS, AFFILIATES OR OTHER REPRESENTATIVES AND THEIR RESPECTIVE PARENT AND SUBSIDIARY COMPANIES, SHALL NOT BE LIABLE IN RESPECT OF ANY CLAIMS, EMERGENCIES, DEMANDS, CAUSES OF ACTION, DAMAGES, LOSSES, EXPENSES, INCLUDING WITHOUT LIMITATION, REASONABLE LEGAL FEES AND COSTS OF PROCEEDINGS ARISING OUT OF OR IN CONNECTION WITH THE USE AND/OR DISSEMINATION OF PERSONAL DATA RELATING TO YOU IN ACCORDANCE WITH THIS PRIVACY STATEMENT AND YOUR CONSENTS.

14. WILL THIS PRIVACY POLICY CHANGE?

To accommodate changes in our services, changes in technology, and legal developments, this Privacy Policy may change over time without notice to you. We may add, change, or remove portions of the Privacy Policy when we feel it is appropriate to do so. We encourage you to review our Privacy Policy periodically. Each time you submit personal data or use our services you agree to be bound by the then current terms of the Privacy Policy. Whenever we update the Privacy Policy, we will change the date to indicate when the changes were made. This privacy policy was last updated on 7^th October 2020.