Privacy Policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of this Site, including any data you may provide through this Site when you buy an App, or contact us for any other reason.

1. Who are we?

Special iApps C.I.C. owns and operates the Site and Apps, is the data controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Full name of legal entity: Special iApps C.I.C. (CRN: 07585386)

Email address: support@specialiapps.org

Postal address: Portland House, Belmont Business Park, Belmont, Durham, United Kingdom, DH1 1TW

Telephone number: +44 (0) 191 389 6638

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 10th June 2021. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of an App or the Services.

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 by contacting support@specialiapps.org.

3. Third-party links

We may at times direct you to third-party websites, plug-ins and applications, and this 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 Site or Apps, we encourage you to read the privacy policy of every website and/or app that you visit.

4. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name, work role and organisation where you work (where relevant);
• Contact Data includes address, email address and telephone numbers;
• Technical Data includes internet protocol (IP) address, browser type, device type and language settings; and
• Usage Data is limited to information about registration (required in order to download free resources) and, only to the extent necessary, to enforce product licensing.

We may also collect, use and share anonymous aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the Site.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If any communication you send to us includes details of any health or medical condition or any special needs of any person we will not process that information other than to answer any specific query from you and emails will be retained in line with our retention policy.

5. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with digital content). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. How is your personal data collected

We use different methods to collect data from and about you including through:

6.1 Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:

6.1.1 you visit our Site;

6.1.2 you sign up to a free trial or subscribe to an App; or

6.1.3 you subscribe to our mailing list;

6.1.4 you register to download add-on resources;

6.1.5 you report a problem with an App or Site;

6.1.6 you request promo codes for an App;

6.1.7. we meet you at a conference, exhibition or workshop;

6.1.8 you contact us using our Contact Us section of the Site.

6.2 Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies, and this is aggregated and anonymised to help provide us with insights as to how our Site is used. As above, this data will not directly or indirectly reveal your identity. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

7. Reasons why we use your personal data and our lawful bases for processing

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 you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

We have set out below, in a table format, the ways we use your personal data, and what our legal justification is for doing so. We have also identified what our legitimate interests are when appropriate.

8. Third-party marketing

We do not share your personal data with any third party for marketing purposes.

9. Cookies

For information about how we use cookies, please see our cookie policy at www.specialiapps.org/en/cookie-policy.

10. Disclosures of your personal data

We share your personal data with the parties set out below:

10.1 With our mailing list and product registrations platform provider, MailChimp (based outside the EEA).

10.2 With our customer relationship management provider, Salesforce.com (based outside the EEA).

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.

11. International transfers

Some of our third parties may process our personal data outside of the European Economic Area (EEA) such as email providers. We review the data protection terms of these suppliers to ensure that your personal data will only be transferred outside of the EEA, if sufficient appropriate safeguards are in place.

12. Data Security

We have put in place appropriate security measures 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.  

We will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collect 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.

Details of retention periods for different aspects of your personal data are set out below:

14. Your legal rights

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

Request access to your personal data (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.

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

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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 information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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. 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

15. Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted in this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

16. Contact us

If you have any questions about this privacy policy, please contact us using the details we have provided to you at the beginning of this policy.