For any support issues, please email email@example.com
The following principles are complied with when processing personal data:
The lawful basis of processing of data will always be determined prior to any data being processed. The laws for processing personal data under the GDPR are as follows:
CloseComms processes personal data under one, or more, of the following Lawful Bases:
When you download and use our apps, you will be asked to give permission for Location-based Services. We automatically collect certain information connected to your Wi-Fi enabled device:
Information we collect when you join the Wi-Fi or use the app:
If your phone or other Internet-connected device is equipped with Global Positioning System (GPS), we may obtain, access, or use such GPS information for the provision of our Services. We collect your geolocation data from your device only after you explicitly give your permission for us to do this through the prompts appearing in the App.
If connecting via the Android or iOS app, we do not need your telephone number and email address. Therefore, we do not collect your phone number or email address, unless you optionally, and explicitly, provide it when if you leave store feedback within the app. If, however, you are connecting with an alternative device (e.g. laptop) then we do ask you for these details.
Information we collect about your Location:
CloseComms may make interactive features such as games available through the App, which may include public leaderboards. To be added to such a leaderboard with your game score you may choose to go public and provide us with information such as a pseudonym, an online identifier, or your name. Your public information includes said pseudonym or name and metadata provided with it. CloseComms may disseminate this information, meaning it will be visible to other users. When you share information or content like your pseudonym or name, you should think carefully about what you are making public.
Information you may choose to provide directly through the app:
CloseComms’ website can be found at https://closecomms.com (“Website”). If you come to our Website, we use Google Analytics to aid us in providing you with information and in continuing to improve upon the provision and maintenance of such Services.
You may also use our contact information on the Website to contact us through a medium on your side (telephone, email, or postal service) and provide us with any information you wish to share through the medium of your choosing.
You can enjoy additional benefits in the App by optionally signing-in via social media platform integrations. If you choose to do so, we collect the following additional information according to the social media platform you choose to sign-in with:
You can withdraw your consent for sharing this information at any time by signing-out of the App. We never post to, or comment in your social media account.
We will retain your information for as long as is necessary to provide you with Services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain and use your information to make promotional offers to you as described, unless you have opted out of receiving such communications.
Data is stored on servers in accordance with local regulations. All personally identifiable information is deleted from our servers after 13 months. The data that we collect from you may be transferred to, and stored at, a destination outside the USA. It may also be processed by staff operating outside the USA who work for us or for one of our suppliers.
Our Application and Services, as well as our Website, are not designed to attract individuals under the age of 13. We do not collect or store any personal information, even in aggregate, about children under the age of 13. If we discover we have received any information from a child under the age of 13 in violation of this policy, we will delete that information immediately. If you believe that CloseComms has any information from or about anyone under the age of 13, please contact us at the contact points specified below.
We will use your information
Your information is aggregated and shared with our Business Partners. We do not provide any personally identifiable information to any other third parties for any reason, except as outlined below in 7.2.
We do so to provide insights about customer behaviors based on the collection of GPS and Wi-Fi location. Your information is analyzed and processed to create anonymous aggregate reports before sharing. For example, reports are created to detail how many people visited a store, and the gender percentage, if such information is available. This information is used to improve the experience of the Services.
We share the following non-aggregated data with our business partners:]
We share information collected through our Apps (Section A), information you provide directly through our Apps (Section B), and information collected from social media platforms (Section D) with our hosting vendor/s and our infrastructure support vendor/s. At present they are:
In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
With regard to geolocation, you may at any time opt out from further allowing CloseComms to access location data by adjusting your permissions in your mobile device. With regard to push notifications, you may at any time opt out from further allowing CloseComms Lab to send you push notifications by adjusting your permissions in your mobile device.
You may stop using the Service at any time by discontinuing the App and uninstalling it.
We maintain safeguards designed to protect the information that we collect about you against accidental or unauthorized access or disclosure. However, protecting your information is a shared responsibility. We protect your personal information according to industry standard. We cannot control how third parties choose to use your personal information. You can protect your information by notifying us immediately of any suspicious activity.
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Individuals (‘Data Subjects’) have the right to obtain:
How do individuals (‘Data Subjects’) submit requests for their information?
The information CloseComms Ltd hold is available upon request by contacting firstname.lastname@example.org.
Individuals can also request their data is updated and/or deleted at any time, unless CloseComms Ltd needs to retain it for legitimate business or legal purposes, by submitting a request to this email address.
CloseComms Ltd may ask the individual to verify their identity before their request is actioned.
CloseComms Ltd has the right to ask the individual for enough information to judge whether the person making the request is the individual to whom the personal data relates. This is to avoid personal data about one individual being sent to another, accidentally or as a result of deception.
CloseComms Ltd has the right to ask for information that is reasonably needed to find the personal data covered by the request. If no personal information about the individual is held, they will be informed.
If data processing is outsourced, subject access requests may be sent to the third party to respond.
CloseComms Ltd will refer to the Company’s GDPR Data Register to locate all the information held on the individual and liaise with the CloseComms Ltd Departments and/or Third Parties concerned in order to collate all the information.
Information will be provided within at least one month of receiving the request. Where requests are complex or numerous, CloseComms Ltd has the right to extend the deadline for providing the information to three months. However, a response to the request explaining why the extension is necessary, will be sent within one month.
Data Access Requests that are manifestly unfounded or excessive can be refused or a charge be made. If a request is refused, the individual will be informed as to why and advised that they have the right to complain to the ICO and to a judicial remedy. The refusal will be made without undue delay and at the latest, within one month.
Information will be provided free of charge.
If you have any questions regarding this Policy, or are required to contact by the terms of this Policy, or if there are any privacy-related errors you wish to correct, please contact us by any of the following methods:
The materials contained on our app are provided for general information purposes only and do not claim to be or constitute legal or other professional advice and shall not be relied upon as such.
We do not accept any responsibility for any loss which may arise from accessing or reliance on the information on this app and to the fullest extent permitted by English law, we exclude all liability for loss or damages direct or indirect arising from use of this app.
SEARCH4LOCAL BUSINESSES IS AN APP OPERATED BY CLOSE COMMS (UK) LTD ("WE"); WE ARE A COMPANY REGISTERED IN ENGLAND AND WALES UNDER REGISTRATION NUMBER . OUR REGISTERED ADDRESS IS 11 MARGUERITES WAY, ST FAGANS, CARDIFF, CF54QW. OUR MAIN UK OFFICE ADDRESS IS BEECHWOOD HOUSE, BEECHWOOD PARK, CHRISTCHURCH ROAD, NEWPORT, NP19 8AJ. OUR VAT NUMBER IS [GB 170945300].
Access to our app is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our app without notice (see below). We will not be liable if for any reason our app is unavailable at any time or for any period.
We are the owner or the licensee of all intellectual property rights in our app, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.
You may print off one copy, and may download extracts, of any page(s) from our app for your personal reference and you may draw the attention of others within your organisation to material posted on our app.
You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
Our status (and that of any identified contributors) as the authors of material on our app must always be acknowledged.
You must not use any part of the materials on our app for commercial purposes without obtaining a licence to do so from us or our licensors.
We aim to update our app regularly, and may change the content at any time. If the need arises, we may suspend access to our app, or close it indefinitely. Any of the material on our app may be out of date at any given time, and we are under no obligation to update such material.
The material displayed on our app is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude:
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
You must not misuse our app by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our app, the server on which our app is stored or any server, computer or database connected to our app. You must not attack our app via a denial-of-service attack or a distributed denial-of service attack.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our app will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our app or to your downloading of any material posted on it, or on any web app linked to it.
The Welsh law courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our app.
If you have any concerns about material which appears on our app, please contact email@example.com.