Introduction 


This policy (together with our end-user licence agreement as set out at tikel.me/eula (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of: 


  •  Tikel mobile application software (App) available from the Apple Appstore or Google Appstore, once you have downloaded a copy of the App onto  your mobile telephone or handheld device (Device).
  •  Any of the services accessible through the App (Services).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.


Important information and who we are

 

4CCS Development Ltd is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

If you have any questions about this privacy policy, please use the details set out below.


Contact details

 

Our full details are:

  • Full name of legal entity: 4CCS Development Ltd

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. If you are resident in an EU Member State, you may make a complaint to any competent supervisory authority of an EU member state. 


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 5 February 2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the 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 our relationship with you. 


The data we collect about you

 

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, image.
  • Contact Data: your billing address, and the delivery address, email address and telephone numbers relating to you and your contacts.
  • Financial Data: bank account and payment card details.
  • Transaction Data: includes details about payments to and from you and details of purchases.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
  • Content Data: includes information stored on your device, including friends’ lists, login information, photos, videos or other digital content, check-ins.
  • Profile Data: includes your username and password, purchase history, your interests, preferences, feedback and survey responses.
  • Usage Data: includes details of your use of the App or our Services including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data: includes your current location disclosed by GPS technology or similar technology. 
  • Special Category Data: includes data relating to health, race, sexual orientation, sex life, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data. We never ask for this data but if you include Special Category Data in your Tikel, it will be processed for the purposes of sending your Tikel.

We explain these categories of data below.


We may also collect, use and share 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 App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

How is your personal data collected?

We may collect and process the following data about you:

 

  • Information you give us. This is information (including Identity, Contact, Financial, Marketing and Communications Data and Special Category Data) you give us about yourself and third parties by filling in forms on the App and our Services, or by corresponding with us (for example, by email or chat). It includes information you provide when you download and register to use the App, use or subscribe to any of our Services, search for the App or our Services, make a purchase, share data via the App’s social media functions, enter a competition, promotion or survey, or other activities commonly carried out in connection with an app and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence. 
  • Information we collect about you and your device. Each time you visit or use the App or our Services we may automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies or other similar technologies.
  • Location Data. We may also use GPS technology or similar technology to determine your current location so we can show you the cost of your purchases in your local currency. You will be asked to consent to your data being used for this purpose. If you do not consent, your purchases will be priced in Euros. You can withdraw your consent at any time by disabling Location Data in your settings.
  • Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Device Data from the following parties:

          analytics providers such as Google based outside the EU;


          advertising networks such as Facebook based outside the EU; and


          search information providers Google based outside the EU.
 

    • Financial and Transaction Data relating to your purchases from providers of technical, payment and delivery services such as our payment processing partner(s). If you have consented, your payment card details will also be shared by our payment provider(s) in tokenised form so we can store them for your future purchases.
    • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

    The information you provide to us will include personal data relating to third parties, including the mobile number of the recipient of the Tikel you intend to send. By using our service, you confirm that you have all necessary consents to share any third-party personal data you provide to us.


    Cookies


    We use cookies and/or other tracking technologies to distinguish you from other users of the App, our Services, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or Our Services and also allows us to improve the App and Our Services.


    How we use your personal data

     

    We will only use your personal data in accordance with applicable data protection laws. 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.

    See below to find out more about the types of lawful basis that we will rely on to process your personal data. 


    Purposes for which we may use your personal data

    Purpose/activityType of data Lawful basis for processing
    To install the App and register you as a new App user Identity
    Contact
    Device
    		Your consent
    To process purchases and deliver Services including managing payments and collecting money owed to usIdentity
    Contact
    Financial
    Transaction
    Device
    Marketing and Communications     		Performance of a contract with you
    Necessary for our legitimate interests (to recover debts due to us)
    To manage our relationship with you including notifying you of changes to the App or any Services Identity
    Contact
    Financial
    Transaction
    Device
    Profile
    Marketing and Communications     		Performance of a contract with you
    Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
    Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
    To administer and protect our business and this App including troubleshooting, data analysis and system testingIdentity
    Contact
    Device     		Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
    To deliver content to you
    To monitor trends so we can improve the App
    To measure and analyse the effectiveness of the advertising we serve you     		Identity
    Contact
    Device
    Content
    Profile
    Usage
    Marketing and Communications     		Necessary for our legitimate interests (to develop our products/Services and grow our business)

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


    We may offer certain Services to you which require your specific, explicit consent. These Services are set out below. The App offers you the opportunity to use and participate in these Services and if you consent to any one of more of these Services, we will process your data for the purposes shown below. You may change your mind at any time and opt-out of the services by changing your election within the App.

    Service/activityType of data
    To access your phone camera and/or microphone to enable you to create personalised media for a recipientIdentity
    To enable you to participate in a prize draw, competition or complete a survey Identity
    Contact
    Device
    Profile
    Marketing and Communications
    To deliver advertisements to you about our services

    To make recommendations to you about goods or services which may interest you    		Identity
    Contact
    Device
    Content
    Profile
    Usage
    Marketing and Communications
    To deliver Services where you choose to upload Special Category DataSpecial Category Data
    To show you the cost of purchases in your local currencyLocation
    To store your payment card detailsFinancial

    Disclosures of your personal data

     

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

     

    • Internal Third Parties such as companies in the 4CCS Development Ltd Group acting as joint controllers or processors and who provide IT and system administration services and/or undertake reporting and/or general administration services;

     

    • External Third Parties such as our third-party payment processing partner(s); service providers acting as processors who provide IT and system administration services; professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances;

     

    • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

     

    Data security

     

    All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology OR similar encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the App and our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

     

    Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

     

    We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) OR similar mechanisms and technology.

     

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

     

    Data transfers

     

    We are based in the United Kingdom, which is where we store your data. The Services involve sending data to your chosen recipient, wherever they may be located. In doing so, your data may be transferred to a location that does not have laws that are as protective of personal data as the United Kingdom. Personal data is sent to other destinations in accordance with your instructions and with your consent. 

     

    Data retention

     

    By law we have to keep basic information about our customers (such as Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

     

    In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

     

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

     

    In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.

     

    Third-party links

     

    Our App and Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

     

    Your legal rights

     

    Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

     

    • 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:

    (a) if you want us to establish the data’s accuracy;

    (b) where our use of the data is unlawful but you do not want us to erase it;

    (c) 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; or

    (d) 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.

     

    You also have the right to ask us not to continue to process your personal data for marketing purposes. 


    You can exercise any of these rights at any time by contacting us at [email protected].