Effective Date: 5th January 2024
Simirity Ltd takes your privacy seriously. That is why we will only use your personal information to provide you with the products and services you have requested, as well as to administer your account. We will not sell or share your information with third-parties unless you grant us explicit permission to do so, and we will never use your personal data for any reason other than the reasons described within this policy.
- About our Privacy Policy
Our Privacy Policy outlines your relationship with our company and explains in detail how we use the information that you provide us with on the simirity.com domain.
- About Simirity Ltd
Simirity is the trading name of Simirity Ltd, which is registered in the UK and registered with the UK’s Information Commissioner’s Office under the Data Protection Act 2018. We encourage you to get in touch with any questions you may have about Simirity.
Simirity offers an online service that allows members to create accounts in order to connect to other family members, capture and upload media files (photos, audio, video and documents), create media rich stories (alone or with coauthors), search story inspiration, administer authorised family member accounts, share stories, manage stories, manage family groups, search for stories or media files, view connected family member profiles, comment on other members content (stories or media files) and chat with family, on multiple computer devices and network platforms (the “Service”).
We are transparent about the data we collect about you, how it is used and with whom it is shared.
You can reach us by:
- Post: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
- Email: [email protected]
- Website: www.simirity.com
- Changing your Preferences
If you’d like to change your web, contact or marketing preferences, you can do so at any time. Simply contact us at [email protected] to request the necessary amendments.
- How we do Business
Simirity is committed to upholding and maintaining your personal rights. We operate our business in-line with the European Union’s General Data Protection Regulation and observe your rights to change or withdraw your opt-in options at any time. As part of our ongoing commitment to uphold your rights, Simirity will also extend advice on how you can issue formal complaints to relevant authorities, such as the Information Commissioner’s Office.
- Sensitive Data
Simirity does not collect any sensitive data about you. Sensitive data refers to (but is not limited to) information about your race or ethnic background, religious or political affiliations, trade union affiliations, sexual orientation, criminal background or health background.
- Who our Privacy Policy applies to
This privacy policy has been developed to inform users of Simirity how we use their data. Simirity is a digital service, and we need to process the data of individuals to offer our products and/or services. Bearing that in mind, our Privacy Policy applies to any and all individuals registered with us as a user, customer, administrator or in any other capacity.
- What Information this Policy applies to
There is a lawful basis for processing your data, and this section of our Privacy Policy outlines how this applies to the personal information you provide us with or allow us to collect.
The information this policy applies to includes information that you:
- Provide as part of any registration process
- Provide as part of any campaign creation activity
- Provide in the form of numerical data, metadata or communications
- Give us as part of our ongoing relationship
This policy also applies to information that we:
- Collect relating to how you interact with our website
- Must process to complete purchases and other transactions
- Consent
Please note that when you submit personal data on our website, you are giving Simirity your explicit consent that we can use that data in line with our Privacy Policy.
- Opting-out
After giving Simirity your consent, you are free to amend your consent or withdraw your consent at any time. You have the right to object to the processing of your data. To opt-out, change your preferences or revoke your consent, simply contact us by emailing [email protected].
- Data processing
Simirity may process your data based on more than one legal ground.
Circumstances under which we may be required to process your data under more than one legal ground may include:
- Customer Registration, using your identity and contact information. Legally processed to carry out the contact we’ve made with you.
- Processing and/or delivering your order, using your identity, contact information, financial information, financial and transactional data. Legally processed to carry out a contract we’ve made with you and to exercise our legitimate interests to recover debts owed.
- To manage our customer relationship with you, using your identity, contact information, marketing and communications preferences. Legally processed to carry out a contract we’ve made with you, to comply with legal obligations and to exercise our legitimate interests to keep our records updated.
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
- Who is the Controller of Personal Data
Simirity will be the controller of your personal data.
As a data controller, Simirity is legally responsible for the data you provide us with. In honouring that responsibility, we pledge to uphold our commitments under GDPR and the Data Protection Act 2018.
We will only ever use your data:
- In ways that are both fair and legal
- As described within this policy
- In ways that are necessary for the purposes described
In addition, Simirity processes the personal data you submit to us or we collect as a data processor. As part of this role, Simirity takes all necessary precautions to secure the personal data we collect, process and store.
We may occasionally use the data you provide us with for marketing, relationship management or account management activities. These activities are designed to ensure you have adequate information about other products and/or services we offer, that we have reason to believe you may be interested in. You have the right to opt-out of these activities at any time.
- What Personal Data do we Collect and for what Purposes
We collect data submitted by you.
If you are simply visiting simirity.com you do not have to provide any personal data. We ask you for personal data when you signup to the newsletter, contact us via the Contact Us form, or when you register to join the Service.
12.1 Personal Data – GENERAL
This information is directly submitted by the user.
Name; You provide us your name when you signup to the newsletter. We use your name in email communications and as a way to identify you. You provide your name when you contact us asking a question. This helps us with the communication process. You provide us your name when registering to join the service. You name is the main identifier of your profile, which makes it convenient for family to find you and interact with you on the basis of your name. It may also used by Simirity as a profile identifier. Your name is not shared with third parties outside of the terms outlined in this Privacy Policy.
Email; You provide us your email address if you choose to subscribe to our newsletter. You may unsubscribe at any time by following the link at the bottom of any newsletter or emailing [email protected] . You provide us your email address when you contact us via the Contact Us form. This is necessary in order for us to reply to your message. You provide us your email address when you join the Service. This is necessary so we can verify you own the email address, and then show your email to profiles you wish to connect to as a form of personal identification. In addition, your email may be used by Simirity for service related emails and optional newsletters. We do not share your emails with third parties outside of the terms outlined in this Privacy Policy.
Country; This is optionally provided by you as part of your profile information. This information is made available to connected family members as your country may be of interest to them. We do not share this information with any third parties outside of the terms outlined in this Privacy Policy.
State / County; This is optionally provided by you as part of your profile information. This information is made available to connected family members as your state / county may be of interest to them. We do not share this information with any third parties outside of the terms outlined in this Privacy Policy.
Telephone; This is optionally provided by you as part of your profile information. This information is made available to connected family members as your telephone number may be of interest to them. We do not share this information with any third parties outside of the terms outlined in this Privacy Policy.
Birth Date; This is optionally provided by you as part of your profile information. This information is made available to connected family members as your date of birth may be of interest to them. The Service uses your birth date to determine your position in family lists (contacts are shown from eldest to youngest) in order to help Users quickly find people of interest. We do not share this information with any third parties outside of the terms outlined in this Privacy Policy.
12.2 Personal Data – USAGE
Data we collect about you when you are on a simirity.com domain.
IP address; We use cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
Device & Location; We receive data from your devices and networks, including location data. When you visit or leave simirity.com (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use simirity.com from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.
Usage Data; We log usage data when you visit or otherwise use simirity.com, such as when you view or click on content. Google Analytics and Hotjar are used to capture and analyse navigation data prior to logging into the Service. Within the app, usage statistics are privately saved on our harddrives using Matomo, to enable us to continuously improve the Service.
- How we Respond to Do Not Track Signals
Simirity does not respond to the DNT settings.
- Direct Marketing, Automated Decision Making and Profiling
Your Personal Data is used for service related emails and newsletters to users who opted into them, in accordance with the Terms. Your Personal Data is not used for other direct marketing campaigns, nor is it use for automated decision making or profiling.
- How Long we are going to Store Data
Any newsletter subscription data is kept so long as you are a subscriber. You may unsubscribe at any time and your data will be removed.
Your profile information and any data you submit to Simirity in the form of stories, media files and comments are saved indefinitely for future generations. However, you may at any time delete specific stories from within the Serivce. Or you can delete your entire account and all information about you, your stories, media files and comments by sending a written request from the email address of your Simirity account to [email protected].
Simirity stores data relating to transactions, payments and orders for a period of up to seven years. This period may be extended under certain circumstances as part of our ongoing commitment to comply with UK and international law.
We use carefully selected and recognised third-parties to help us take payments, provide commerce services and manage company accounts. Some of these third-parties may operate outside the European Union.
- Storage and transfer of data (internationally)
We take appropriate technical and organisational measures to ensure the protection of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular but not limited to where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.
Simirity, in line with this, among other things, applies different levels of access rights to the data, which ensures that only the appropriate authorised person has access to the data, whose knowledge of the data is necessary to fulfil his or her obligation arising out of or in connection with the performance of his or her job.
- Legitimate Interests
As part of the Data Protection Act 2018, Simirity observes the right to share selected information with third-parties that use data for non-marketing purposes. This could include (but is not limited to) organisations that provide credit assessments, identification services and fraud prevention activities.
- With what Third Parties we share the Data
We do not sell your Personal Data. We may use others to help us provide the Service ( e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.
We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.
- Your Rights
For personal data that we have about you, you have the right to:
- Delete data (the right to erasure): You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Change or correct data (the right to rectification): You can edit some of your personal data through….. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
- Object to, or limit or restrict, use of data (the right to restrict processing and the right to object): You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to access and/or take your data (the right to be informed, the right of access and the right to data portability): You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
- How you can Exercise your Rights
If you have any questions regarding our collection and usage of your personal data, please contact us at [email protected].
You also have the right to contact and lodge a complaint with the local data protection authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.
You can also contact the Information Commisioner’s Office at https://ico.org.uk/make-a-complaint/data-protection-complaints/personal-information-complaint/.
- How we will Inform you that our Policy has Changed
Simirity is constantly evolving, which means we get new data and create new ways to use data. We will introduce new features, which may require the collection of new information.
If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy: we will provide notice on simirity.com, or by other means, to provide you with the opportunity to review the changes before they become effective.
You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.
- Marketing and Communications
Simirity may send you marketing communications if you have given us your contact details and opted-in to marketing communications.
You can opt-out of these marketing communications and manage your preferences at any time.
- Our Security
As part of our ongoing commitment to GDPR, Simirity will report any security breaches or attempted breaches to the relevant authorities within 24 hours. We will subsequently contact all those affected by the breach within 72 hours of its occurrence.
- Contact us
Simirity is committed to upholding your rights. If you have any questions, comments or concerns about this privacy policy or wish to exercise your rights in relation to your personal data, please contact [email protected].
We will process any request within 20 days. Subject Access Requests are normally performed free of charge, but we may need to charge individuals for excessive or unreasonable data requests.