We are Zerdalab Limited (registered company number: 13566076) of Saffery Champness LLP 4th Floor St Catherine’s Court, Berkeley Place, Clifton, Bristol, United Kingdom, BS8 1BQ, and we are the creators of “PDC Dull Grade” app (referred to below as the ‘app’).
It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of your information obtained via the app, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
If you are aged under (or under the age of the majority or minimum working age in your jurisdiction) you must not use the app as it is not designed for you.
The app may link to other apps, websites or services owned and operated by certain third parties. These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.
The information we collect about you depends on the particular activities carried out through the app. We will collect and use the following information about you:
Category of data
In more detail
Identity and account data you input into the app
Registration is mandatory in order to use the app
· your name and contact information, including email address and telephone number and, where applicable, your company details
· your account details, such as username and password
· your replies to security questions
· payment or other financial details (e.g. payment card information, bank information)
· other related information
Data collected when you use specific functions in the app
· data you store online with us using the app (while such data may not always be protected by the UK GDPR we will assume it is and treat it in accordance with this policy)
Data collected when you permit the collection of location data
· details of your location, see the section ‘Location services/data’ below
Other data the app collects automatically when you use it
· your activities on, and use of, the app which reveal your preferences, interests or manner of use of the app and the times of use
Data collected from third parties
· occasionally we may receive information about you from other sources (such as your employer if you are their authorised user), which we will add to the information we already hold about you in order to help us operate our business effectively.
You must provide this information to use the app and its services unless we tell you that you have a choice. Sometimes you can choose if you want to give us your information and let us use it. Where that is the case we will tell you and give you the choice before you give the information to us. We will also tell you whether declining to share the information will have any effect on your use of the app or our services.
The app will request your consent to use location services to precisely identify your location each session (i.e. each time the app is opened or has been placed in the background). We require access to that data in order to set your location in your app profile.
If you do not provide your consent, you may use the app but that will mean that feature on the app will not be available. To withdraw your consent at any time (that will not affect the lawfulness of our use of that data in reliance on the consent before it was withdrawn) by contacting us (see ‘How to contact us’ below).
The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time.
Under data protection law, we can only use your information if we have a proper reason, e.g.:
Our main processing activities for personal data, and the legal basis on which we perform those activities are:
Prospective customers/marketing recipients:
We may process your personal data in order to contact you in relation to our products and services and keep a record of our communications (e.g. sales telephone calls, quotations and offers).
Our legal basis for doing so is our legitimate interests, which allows us to market our products and services to individuals provided there is a business case for doing so and our interests do not override the rights of the individuals in question. If you wish to object to direct marketing, you may do so by contacting us.
We will process your personal data in order to provide our app, as well as our products/services, to you and to provide you with information and updates regarding the same. Our legal basis for doing so is that the processing is necessary for the performance of a contract. We will also keep a record of your data and use it for related purposes, including account management, customer support, and audit purposes, on the basis that we have a legitimate interest in doing so.
We may also contact you in relation to our products and services. Our legal basis for doing so will be the same as for prospective customers, as set out above.
Our other processing activities are:
Our search will be recorded on the files of the credit reference agency. We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked. Other credit businesses may use your information to:
If you provide false or inaccurate information to us and we suspect fraud, we will record this.
We routinely share your information with:
We only allow the companies referred to above to handle your information if we are satisfied they take appropriate measures to protect your information. We also impose contractual obligations on service providers to ensure they can only use your information to provide services to us and to you.
We keep your personal information for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal information to comply with our legal and regulatory requirements.
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your information to countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your information.
We store your personal data on cloud-based servers based in the .
Under data protection laws, we will only transfer your information to a country outside the UK where:
You are responsible for ensuring that information you provide to us is accurate, complete and up-to-date. You can review and change your information by contacting us.
You have a number of rights in relation to your personal data, these include the right to:
If you would like to exercise any of your rights or find out more, please contact us.
We will use technical and organisational measures to safeguard your personal data, for example:
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).
Policy version: Jan 2023