Livappool Limited t/a Starship Privacy Policy (version 1, 26 january 2015)

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At Starship, your privacy is very important to us. As part of our business, we design mobile apps for children. When we do so, we are committed to providing a safe environment for children and creating a brand that parents can trust.

Please take the time to read and understand this policy. By using our websites and mobile apps, contacting us by telephone or email or providing information to us by way of social media, you agree to its terms.

To help you, we’ve included some links to other websites. It’s worth remembering though that other people, not us, control these websites. We’re not responsible for them.

1. What INFORMATION do we collect and when?

We collect:

-All information you choose to provide to us. For example, if you submit your name or email via our website.

-Information on what you view, click on and access through our marketing emails, websites and mobile apps. For websites, this information may the site that you came from, and where you went when you left our site.

-Technical information about the devices you use to access our websites. We collect each device’s manufacturer and model, relevant IP address, operating system and version, web browser and version, and geographic location.

-Your social media content where this is in the public domain, and any messages you send direct to us via social media. This information can include posts and comments, pictures and video footage on sites such as YouTube, Facebook and Twitter.

 

2. HOW DO WE COLLECT YOUR INFORMATION?

We collect information on you through:

-our websites and mobile apps and your use of them, including completing any other forms, and signing up for marketing communications from us;

-emails you send to us, or that we send to you;

-our conversations with you;

-your use of social media, including “like” buttons and similar functions made available by social media platforms.

 

3. WHAT ABOUT CHILDREN’S PRIVACY? 

We are sensitive to privacy issues and look to protect your child’s information.  We also strive to be fully compliant with the United States’ Children’s Online Privacy Protection Act (COPPA).  We strongly encourage parents and guardians to regularly monitor and supervise their children’s online activities.  We do not knowingly collect any personal data such as name, postal address, email address, telephone number or geographic location information (“Personally Identifiable Information”) from children under 13 on our websites or mobile apps without first obtaining verifiable consent from the child’s parent or guardian.

If we ever collect such Personally Identifiable Information, we will not require your child to provide more Personally Identifiable Information than is reasonably necessary to participate in an activity.

Please also note that we do not offer activities that require the ongoing collection and use of Personally Identifiable Information provided by children, so we will seek your permission each time we need to collect Personally Identifiable Information from your child.

If you would like to review Personally Identifiable Information about your child that we have on file, or request that certain information be changed or deleted, please send an e-mail to privacy@starship-group.com.

NOTICE: Visit http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online for information from the Federal Trade Commission about protecting children’s privacy online.

If a child under the age of 13 has provided Personally Identifiable Information on one of our websites or mobile applications without the consent of his or her parent or guardian, we ask that a parent or guardian send an e-mail to privacy@starship-group.com, and we will delete the child’s Personally Identifiable Information from our files.

Please note that our Playworld Superheroes App does not collect any Personally Identifiable Information.  We will never ask you or your child for any such Personally Identifiable Information or direct them out of the App to an external website.  Our Playworld Superheroes App may however collect information about your or your child’s use of the functionality of the App i.e. where you got up to in the game.

 

4. HOW do we use your information?

We use the information we collect for the following purposes:

-To provide you with our websites and mobile apps, which all require a certain amount of technical information to work properly.

-To power our security measures and services so you and your children can safely access our website and mobile apps.

-To reply to any questions, suggestions, issues or complaints you have contacted us about, including to provide you with any technical support you may have requested.

-To respond to any social media posts or other public comments you might make, whether they are directed to us or about us, our websites, mobile apps or other activities.

-For recruitment purposes if you have applied for a position with us including to contact you to discuss a role with us and to assess your suitability. As part of this we may combine any personal data you provide to us with other information we obtain independently from social media sites (e.g. LinkedIn or Facebook).

-To advertise products or mobile apps to you via our email newsletter where you have signed up to this or to tell you about any special offers or exciting competitions. If you stop using our mobile apps, we may try and tempt you back to us.

-To tell you about any changes to our websites and mobile apps. For example, if we withdraw one of our apps for some reason, or change this privacy policy.

-To make a contract with you. But also to enforce a contract if you don’t honour it, including the collection of any debts that we may be owed by you.

-To gather statistics about how you and other people use our website and mobile apps and what you think of our advertisements, special offers, news, websites, mobile apps, competitions, sponsored events, social media and other content. We then analyse all this data to see if what we do is interesting to people and meets their needs, or if they should be improved, and if so, what changes would be most beneficial both for our customers and for us.

-To monitor how people use our websites and mobile apps to see if they are being abused or threatened, for example, by internet trolls posting inappropriate comments in review areas or by would-be hackers looking to undermine our security.

-To protect you and our business from any other potentially criminal behaviour, including identity theft and fraud.

-To allow us to understand our customer base across all our businesses. We do this by merging your details with information from our other customers and users of our websites and mobile apps. We can then spot trends and common factors among users, plus we can tailor our business approach, our marketing communications, our digital and social media, our websites and mobile apps to the things we believe you and other people like you would be most interested in. This process involves the analysis of many human traits and is sometimes called ‘market segmentation’ or ‘customer segmentation’. Among other things, we look at common trends or ‘segments’ based on people’s geographic location, online behaviours on our websites or mobile apps and the features they look for from our mobile apps.

-To communicate with youabout operational changes to our products, services, websites and mobile apps, for example if we were to withdraw one of our apps, or change this policy;

-To assist us in the development of new products and mobile apps over a period of time. For example, we may need to gauge whether a new product or mobile app is likely to appeal to a large proportion of our customer base. And if not, we’ll want to know why.

-To see if the money we spend on marketing and advertising across all media represents good value for us or not.

 

5. WHO DO WE SHARE YOUR INFORMATION WITH?

We will only ever use your personal data for the purposes set out above; we do not and will not sell or trade your personal data.  However, we can’t run our business or provide our mobile apps without involving other people and organisations from time to time. When we share your information, we want you to know that we only do so in accordance with our legal data protection and privacy obligations.

Your information may be disclosed to:

-Companies, brands and businesses within our group for them to use for the purposes set out in this policy. This is because we hope to have a relationship with you across all our different brands and businesses, if not now, then sometime in the future. And we want to be able to provide you with the same high quality experience whenever and however you deal with us.

-With email marketing companies who help us to mail our newsletter to you.

-Any new business partners we may have over time, for example, in the event of a joint venture, reorganisation, business merger or sale that affects us.

-Our professional advisors including our lawyers and technology consultants when they need it to give us their professional advice.

-Law or tax enforcement, the courts and any other government authority if they ask us to do so (but only if us doing so is lawful).

-Other people who make a ‘subject access request’, where we are allowed to do so by law. (See ‘Managing Your Information’ below for what we mean by a ‘subject access request’).

 

We may also share the information we collect where we are legally obliged to do so, e.g. to comply with a court order.

-Social media, blogs, reviews, etc.

Any social media posts or comments you send to us (on our Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they’re written and could be made public. Other people, not us, control these platforms. We’re not responsible for this kind of sharing. So before you make any such remarks or observations, you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you’ll understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you’re unhappy about it.

It’s worth remembering too, that any blog, review or other posts or comments you make about us, our products and services on any of our blogs, reviews or user community services will be shared with all other members of that service and the public at large.

You should take extra care to ensure that any comments you make on these services, and on social media in general are fit to be read by the public, and are not offensive, insulting or defamatory. At the end of the day, you are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.

-Mobile app platforms

Our mobile apps run on third party software platforms, for example, Apple’s iOS platform which powers Apple’s iPhone and Google’s Android platform which powers Android-based smartphones.

If you use any of our mobile apps, your usage of those apps is also subject to the relevant mobile app platform provider’s terms and conditions and privacy policy. You should review their terms and conditions and privacy policy to ensure you understand what information (if any) they will gather about you, how they will use that information, and what you may be able to do if you are unhappy about it.

 

6. INTERNATIONAL TRANSFER OF YOUR INFORMATION

Although we’re based in the UK, we use suppliers and agents from many parts of the world to help ensure you receive the very best in products and services from us.

To allow us to run our business on this basis, the information we collect may on occasion be transferred to, stored and used at premises in other countries including the United States of America.

Naturally, we aim to ensure all our suppliers take information security as seriously as we do.

Even so, information protection laws can vary from country to country.

For instance, the law of the country in which you are resident or domiciled may offer a higher standard of protection than the laws in the UK and/or the other countries in which we store and use the information we collect.  We will always seek to ensure that anybody with whom we share your information who is based outside the UK treats your information in the same way as we are required to in the UK, but you should be aware that any transfer of information we make to other countries could result in that information being available to their government and other authorities in those countries under their laws.

 

7. SECURITY OF YOUR INFORMATION

We take the security of your information very seriously.

We use appropriate procedures and technical security measures to safeguard your information.

If you have any concerns about the security of your own personal computers and mobile devices, we suggest you read the advice of Get Safe Online [www.getsafeonline.org].

 

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We can only keep your information for as long as necessary for the purposes set out above. This restriction is set by the Data Protection Act 1998. The precise length of time we hold your information for varies depending on your individual circumstances.

 

9. MANAGING OUR MARKETING COMMUNICATIONS

We provide ways for you to stop all email communications you receive from us – please see the ‘unsubscribe’ link we include in each email.

If you think that your child has signed up for our newsletter without your permission or would like us to change your marketing preferences at any time, you can contact us on privacy@starship-group.com.

 

10. MANAGING YOUR INFORMATION

To reduce the chances of an error or misunderstanding, we need to keep the information we gather about you is accurate and up-to-date. But whilst we work very hard to make sure mistakes don’t happen, we need your help, too.

Further, if you have reason to believe any of the information we collect on you may be inaccurate, please contact us (see below for how to do this).

You are perfectly within your rights to ask us whether we hold information about you and if so, for us to give you certain details about that information and/or the information itself. This right is commonly known as a ‘subject access request’. Certain exemptions and conditions apply to this right, principally that it should be in writing and that you give us reasonable details about the information you want.

Depending on your country of residence or domicile, you may have additional or different rights to those set out above concerning the information we collect from you and your devices. We will, of course, honour all such legal rights if we are bound by them.

We reserve the right to charge you a small administration fee to meet our costs in honouring your legal rights, where permitted by the relevant law.

We also reserve the right not to comply with any enquiries or requests we receive about the information we collect, where we may lawfully do so. For example, if we have reason to believe that a request is malicious, technically impossible, involves disproportionate effort or could be harmful to others.

If you have any worries or complaints about the way we use your information, please don’t hesitate to get in touch with us. We’ll do our very best to set your mind at rest or put things right. And if, for whatever reason, you feel we’re not meeting the exceptionally high standards we expect of ourselves, you’re within your rights to tell the Information Commissioner’s Office (ICO) (in the UK) or the Federal Trade Commission (FTC) (in the US). Please see the section ‘Where to go if you want more information about your privacy rights’ for further details.

And don’t forget that with modern technology you have more and more personal control over what information we and other organisations collect. For example, you can normally reject or delete cookies and tracking technologies sent to your web browser. You can also change related settings to restrict them going forward, such as by using a private browsing mode (although this may affect your browsing experience on some websites). Plus, you can use the settings options in your mobile devices to restrict what sort of information websites and mobile apps are able to access and use about you. Online advertising networks, social media platforms and search engines (Google etc.) also provide tools to manage the data they collect about you, and how it is used and shared. We urge you to look out for these functions and tools and use them to manage your privacy in a way that suits you best.

11. Updates to this privacy policy

We review the ways we use your information regularly. And in doing so, we may change what kind of information we collect, how we store it, who we share it with and how we act on it.

Consequently, we will need to change this privacy policy from time to time to keep it accurate and up-to-date.

Whenever we change this policy, we will post a revised version to the “Terms and Conditions” section of our websites. That way, you can check to see if you’re still happy. And if, following any changes, you continue to use our websites and mobile apps, contact us by telephone or otherwise provide information to us (through social media, for example) we will assume that you agree to those changes.

 

12. About us

Our full legal name is Livappool Limited.

We’re a limited company registered in England and Wales and our registered address can be found in the ‘contact us’ section below.

We are the ‘data controller’ of the information you provide us with. This term is a legal phrase used to describe the person or entity that controls the way information is used and processed.

We are registered under the Data Protection Act 1998 with the Information Commissioner’s Office in the UK. Our registration number is ZA084192.

 

13. Where to go if you want more information about your privacy rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here: [https://ico.org.uk/].

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.

 

14. Contact us

You’re welcome to get in touch with us to discuss your information at any time. Our contact details are:

Livappool Limited
5th Floor Elevator Building
25-31 Parliament Street
Liverpool
UK
L8 5RN

Email: privacy@starship-group.com

Thank you very much for taking the time to read this document.

Livappool Limited