© 2019 All rights reserved
Dribble Privacy and Cookies Policy
Keeping your data safe
Please click on the headings below for full information about how your personal data is processed.
Who’s in control of my personal data
Although we are legally the “controller”, you can control the personal data that we have access to. Most of the personal data that we will be able to access is personal data that you voluntarily provide and is not mandatory. You have certain rights in relation to your personal data which are detailed in this policy, but if you decide you don’t want us to process personal data about you anymore, you can edit your profile and delete or change your personal data. You can also close your account entirely at any time.
You should also remember that you will upload some information about your children or children who are in your care. We don’t ask you for children’s names but you can assign a nickname to children whose information you upload and those children’s profiles will be linked to yours. If you provide information about someone else’s child you should make sure that the child’s parent or guardian is happy for you to do so.
What data do you collect and where from?
When you register for a Dribble account, we will collect the following mandatory information (we call this Account Information):
your first name and surname;
your email address;
a password that you will set;
your gender; and
information about your relationship to the child or children concerned (i.e. whether you are their parent, guardian, carer or other).
If you choose to sign in using a social media account, we will receive your email address and any of your account data that is publicly available on your profile (such as your name and location).
Once your account is set up and in order to make sure you have the best experience of Dribble, we collect information about your preferences that you choose to add. This information is not mandatory but will help us to make sure that your search results reflect your requirements. This includes:
the age ranges of the children concerned (please note that the age ranges selected will update automatically on a seasonal basis to ensure that they are always up-to-date);
your interests and lifestyle, for example if you like sports, history, art or technology;
your working status, for example if you work full time, part time or if you are on parental leave;
an indication of how active you are;
any “favourites” that you want to set, for example if you would like us to show you breastfeeding-friendly places, places with good vegetarian or gluten-free options or places with good parking nearby; and
you can also choose an avatar for yourself.
You can also choose to add profiles for your children to ensure that your search results are tailored to your child’s personality and needs. This is not mandatory either. We do not ask for children’s real names but each child’s profile that you add will be linked to your profile. If you add a profile for a child, you can choose to provide the following information about that child:
season and year of birth;
interests and information about his or her personality, for example if he or she likes sport, music or animals and if he or she is boisterous or quiet;
level of mobility, for example if he or she is crawling, walking or uses a wheelchair;
needs, for example if you require venues that are autism or epilepsy friendly and if the child has any allergies; and
you can also choose an avatar for each child.
If you use the “Near Me Now” function and you allow us to use GPS to locate you, we will collect information about your location through GPS. We will ask you if you want to use GPS to find nearby places when you set up your account and you can change your mind and turn off GPS at any time in your app or device settings.
Communicating with us and posting reviews
We also collect other personal data you voluntarily provide, for example if you contact us with comments or questions or if you choose to include personal information within a review that you leave. If you leave a review of a venue, unless you choose to post it anonymously, other users will be able to see your first name and town against that review.
We collect some technical information, such as IP address, device identifiers and information about how you use the Dribble app (e.g. which sections of the app you use) through using cookies. Please see the section below headed “Cookies” for more details.
What do you use my personal data for?
Running your account
We use your Account Information to set up and administer your account, allow you to log into your account and make sure that you can use Dribble and all its features. We use your email address to contact you with service messages about Dribble, for example to provide you with password reminders or to let you know if Dribble is experiencing technical issues.
We use the preferences that you submit for you and your children to build a profile of you and your children so that we can show you recommendations for venues and activities that are likely to be relevant and interesting to you. We also use your postcode to show you venues and activities that are near your home. When you search for a type of venue, or apply search filters, we will use this information to process your search request and show you results that are relevant to your request. We will sometimes combine this information with your preferences and your profile to make sure that we show you things that are useful to you. For example, if we know that your child is in a pushchair and you search for a coffee shop, we will show you recommendations for coffee shops that don’t have stairs.
We sometimes use information that we know about you to infer information about what another user of the app might like. For example, if we know that you have a two-year-old who likes the outdoors and you have visited and liked a particular venue, we will suggest this venue to another family with an outdoorsy two-year-old.
If you use the “Near Me Now” function and allow us to use your GPS location, we use this to show you venues and activities that we think you will enjoy near your current location.
Communicating with you
We use information that you voluntarily provide to us when contacting us with queries, comments or complaints to enable us to respond to those queries, complaints or comments and to make sure that these are appropriately dealt with.
Some of the communications we send to you, such as reminding you to complete a review that you have already started, may be sent by push notification. Push notifications are messages that pop up on your mobile device. You can choose whether or not to receive push notifications from Dribble through your device settings.
Analysing and improving Dribble
We use your personal data, including your gender and the technical information we collect about how Dribble is used, to help us to monitor trends so that we can analyse and improve Dribble. This helps us to make sure that we are providing you with the best possible service.
Marketing and competitions
Where you have consented to us doing so, we will use your email address, telephone number and/or postal address (depending on the method(s) of marketing you choose) to send you direct marketing communications. You can choose not to receive these communications by following the instructions in each communication to unsubscribe. Where you have consented to us doing so, we will also use these details to send you communications about promotions or discounts that are being offered. If we run competitions we will use your information to enable you to participate in the competition and to contact you if you win a prize.
If you leave a review, we will display your review, together with your name and town, on the venue you have left a review for. You can choose to post your review anonymously, in which case your name and town will not be shown.
What is your legal basis for using my personal data?
Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. The table below tells you what that legal basis is in relation to each of the purposes set out above.
|Purpose||Personal data used||Legal basis|
|Running your account and providing Dribble to you, including contacting you with service messages and the “Near Me Now” function||Account Information (except gender and postcode)||We process this personal data for this purpose on the basis that this information is necessary in order to perform our contract with you to provide Dribble and to allow you to use Dribble.|
||Postcode and preferences that you submit for yourself and your child||We process this personal data for this purpose on the basis that this information is necessary for our legitimate interests. We have an interest in ensuring that Dribble is as relevant as possible so that you have a tailored and useful experience of using Dribble. Where preferences submitted include special category personal data, we process this on the basis that we have your consent to do so (which you provide by including the special category data). You can withdraw your consent at any time by editing your or your child’s profile to remove this information.|
||GPS data||We process this personal data to enable you to use the “Near Me Now” function on the basis that this information is necessary for our legitimate interests. We have an interest in ensuring that Dribble is as useful to you as possible so that our users have a good experience of the app.|
|Monitoring trends, analysing and improving Dribble||Account Information (including gender) and preferences plus the technical information that we collect about your device and how you use the Website||We process this personal data for this purpose on the basis that this information is necessary for our legitimate interests. We have an interest in ensuring that we continue to improve Dribble and provide our users with the best and most effective app possible.|
|Responding to queries and comments or other messages||Your Account Information and any other information you voluntarily provide to us when contacting us||We process this personal data for this purpose on the basis that this information is necessary for our legitimate interests. We have an interest in making sure that comments and queries are handled appropriately so that they can be resolved for our users.|
|Marketing||Your email address, telephone number and/or postal address||We process this personal data for this purpose on the basis that we have your consent to do so. You can withdraw your consent at any time by following the “unsubscribe” instructions in marketing communications or by changing your account settings.|
Who do you share my personal data with?
Other users will be able to see your name and town if you post a review of a venue, unless you choose to post the review anonymously.
We use third party service providers to carry out the following services on our behalf:
developing, hosting, maintaining and supporting the app;
providing our document management system, database and content management system; and
marketing and communication services, including sending newsletters and notifications to users who have opted in, helping us to send marketing that is more useful for users and managing marketing opt-outs.
- Those third party service providers will have access to your data as part of performing their services for us. They do not use your data for any other purposes.
We also use Google Analytics and Facebook Analytics to analyse trends and improve our app. You can find more information about this in the section headed “Cookies” below.
If you choose to share a venue via social media, the social media network you share it to will know that you visited that page within Dribble, in order to be able to share it.
Whereabouts is my personal data kept?
We use Mailchimp to help us manage our newsletters and notifications, including sending newsletters on our behalf, helping us to ensure that newsletters are as useful as possible to our users and managing marketing opt-outs. This means that if you have opted in to receiving marketing information from us, your personal data will be shared with Mailchimp to allow them to provide these services to us. Mailchimp is based in the USA and is certified with the EU-US Privacy Shield framework. This means that Mailchimp protects your personal data in the USA in a way that has been approved by the European Commission. You can find out more about Privacy Shield, and Mailchimp’s certification, here.
How long do you keep my personal data for?
We will keep all your personal data for as long as your account remains open. You can close your account at any time using the “Get in Touch” page of the app. If you close your account, we will delete the personal data associated with your account. It will take 30 days for this personal data to be deleted. This will delete your profile and associated information, but please note that reviews you have posted will be anonymised so that they show as having been contributed by an anonymous user (your name and town will no longer be shown). Any personal data about yourself or others which you have included in the content of the review will not be deleted.
You can delete reviews you have posted by going to your profile and viewing all previous reviews then selecting “Delete” next to the review you wish to delete.
If your account is inactive for a period of eighteen months, we reserve the right to close your account and delete your personal data in accordance with section 8.1 above.
We occasionally need to keep data after account closure for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes.
What rights do I have?
You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
If you want to exercise any of these rights, please email us at email@example.com or write to us at Dribble Ltd, 51 Lilyhill Terrace, Edinburgh, EH8 7DR. You can also use the “Contact” section of our website (www.dribbleit.co.uk) or the “Get in Touch” page of the app.
A right to access your information
You have a right to ask us to send you a copy of all the personal data that we hold about you (subject to some exceptions).
A right to an electronic copy of your information
You can also ask us to send you the mandatory Account Information that we hold about you in a common electronic format, or to ask us to transfer that data to a third party if you want us to and if it is technically feasible for us to do so.
A right to object to us processing your information
You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing (as set out in section 5 above). This includes non-mandatory data about your or your child’s preferences, GPS data and information you voluntarily provide, for example when you contact us. Remember that you can edit your profile at any time and change or remove any of your or your child’s preferences. You can also choose not to have us collect your GPS data when you use the “Near Me Now” function (either when you set up your account or through your app/device settings).
If you make a request to exercise your right to object, if we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
Remember that as well as editing your profile, you can always delete your account at any time by using the “Get in Touch” page of your profile. You can also delete reviews that you have made by viewing all previous reviews and selecting the “Delete” option.
A right to ask us not to market to you
You can ask us not to send you direct marketing. You can do this by following the “unsubscribe” instructions in any marketing emails or by changing your account settings, or by contacting us using the details above.
A right to have inaccurate data corrected
You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
You can update your own personal data at any time by editing your profile. It is your responsibility to ensure that your personal data is accurate and up-to-date. Please note that the age ranges that you select for any children whose profiles you add will be updated automatically on a seasonal basis to ensure that they are kept up-to-date.
A right to have your data erased
We will delete the personal data associated with your account, including any posts you have made, when you close your account, as set out under “How long do we keep your data for?” above. Remember that you can close your account at any time or delete personal data within your account and you can delete your own reviews by selecting the “Delete” option when you view all reviews in your profile.
A right to have processing of your data restricted
You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.
Restricting your personal data means that we only store your personal data and don’t carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.
We use different types of cookies to do different things:
Some of our cookies are “strictly necessary”. These are cookies that are required for Dribble to operate. For example, we use a cookie to log you into Dribble and make sure that you can access the information contained within Dribble. Dribble can’t function without these cookies.
Some cookies are call “functional cookies”. These are used to recognise users when they return to Dribble and to save your preferences. For example, we use a cookie to remember your username and password details so that you don’t have to input your details every time you open Dribble.
We also use analytical cookies which allow us to recognise and count the number of app users and see how users are using Dribble. This helps us to improve Dribble, for example by ensuring that users are easily finding what they are looking for. We use Google Analytics and Facebook Analytics for this. These cookies do not collect any data which directly identifies you and all information is aggregated, so that we cannot see what particular users do but instead we see trends and patterns.
Please visit www.allaboutcookies.org, www.aboutcookies.org or www.whatarecookies.com to find out more about cookies and how to opt out of cookies on your device.
How can I contact you?
What if I have a complaint?
You have a right to complain to the Information Commissioner’s Officer (ICO), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data.
You can find out how to do this by visiting www.ico.org.uk.
What if this policy changes?
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