Privacy & Cookies Policy – Schappit Ltd / Piota Apps
This is the Privacy & Cookies Policy (the ‘Policy’) of Schappit Limited (trading as “Piota Apps”) (hereafter ‘Schappit’, ‘we’ or ‘us’).
Schappit provides the Piota App (the “App”) to clients in different industries e.g., schools, clubs, charities, churches, healthcare and others (each an “Organisation”). The App is designed to facilitate the provision of information about the Organisation in question. The App collects and uses certain information about you which is processed by Schappit on the Organisation’s behalf. If you are an employee or other staff member of an Organisation who has registered with Schappit for Schappit to provide you with the App then Schappit may also collect certain information about you in order to provide the App to your Organisation.
This Policy describes the ways in which: (i) Schappit and the Organisation collects and uses information about you when you download and use the App on your phone or device; (ii) Schappit collects and uses information about you if you contact Schappit or if you make a comment or complaint to Schappit about the App (iii) if you are an Organisation, the ways in which Schappit collects and uses information when you engage us to provide the App to end users; or (iv) if you visit our website at www.piota.co.uk (the ‘Website’).
1. General: By downloading and/or accessing the App you agree to be bound by this Policy in respect of the information collected about you as further described in Section A. If you are an Organisation and you enter into a separate agreement with us to provide the App to end users you agree to be bound by this Policy in respect of the information collected about you as further described in Section B. By contacting us to comment or complain you agree to be bound by this Policy as described in Section C. By visiting our Website you agree to be bound by this Policy in accordance with Section E. Schappit may change this Policy at any time in which case we shall notify you of any changes to this Policy.
SECTION A – Your use of the App
2. What the App Does: The App allows you to receive information and updates managed by the Organisation. For the purposes of data protection legislation, the Organisation shall be the ‘data controller’ responsible for how your information is used and Schappit shall be the ‘data processor’ acting on behalf of the Organisation. If you have any concerns in relation to the way your information is presented or is used by the App please contact Schappit or your Organisation.
3. Information which is collected by the App: The Organisation will collect some or all of the following information using the App (depending upon how you use it yourself) which is processed and shared with Schappit:
- any information which you enter into the App, for example when completing a form or a survey provided by your Organisation via the App;
- information that you submit to Schappit when you sign-up to register for the App (where such registration option is provided), being your e-mail address and/or phone number;
- certain analytical information that Schappit will collect from you as you use the App, for example how many downloads of a form you complete, the number of users on a page at any particular time and so forth (“Analytical Information”). Schappit may combine the Analytical Information in certain circumstances with the information provided in 2(a) and (b) above. Schappit may also collect your Unique Device Identifier or a record of the internet browser which you are using when you use the App. This may provide an approximate location as to where you are using the App and on what device; and
4. Information which is processed by the App: The Organisation may add its existing records in relation to you (and, if you are a parent or guardian of a child at a particular Organisation, any child to whom you are the parent or legal guardian) to the App to assist the Organisation in relation to the tasks outlined in paragraph 5. This information will include any or all of the following information (depending on what your Organisation chooses to provide to Schappit and the nature of your Organisation): your name, your phone number, your email address, your gender and in the case of e.g. a school App that you have downloaded as a parent or guardian, your child’s name, gender, year group, class and other details about you and your child including e.g., photos of your child when participating in specific Organisation events. If you have any queries or concerns in relation to any such information please contact the Organisation. Schappit shall process all such information in accordance with this Policy.
5. How the information about you on the App is used: The information about you described in paragraphs 3 and 4 will be used by the Organisation and Schappit as follows:
a. all of the information listed in paragraphs 3 and 4 above will be used to enable the Organisation to undertake communication and administration tasks in relation to the management of the Organisation, including but not limited to:
i. dissemination of information about the Organisation’s activities to you and other App users, e.g., updating you in relation to activities, events and news relating to the Organisation and organising meetings;
ii. obtaining consents when required for activities such as Organisation trips, marketing purposes and taking and publishing photographs on the Organisation’s website;
iii. providing feedback on the Organisation through surveys;
iv. if your Organisation is a school, children’s club or similar, recording information in relation to pupils, for example absences, commendations, disciplinary occurrences and other attainment and progress measures;
v. recording information such as contact details;
b. the Analytical Information listed in paragraph 3(c) and the cookies information in 3(d) will be used to tweak, tune and facilitate the improvement of the App and your experience of the App;
c. if the Organisation chooses to permit the App to be used for advertising, all of the information listed in paragraphs 3 and 4 may be used to provide advertising within the App to you (for example, based on your location and information about you which has been anonymised).
d. all of the information listed in paragraphs 3 and 4 will be used to allow you to communicate with the Organisation;
e. all of the information listed in paragraphs 3 and 4 will be used to provide technical support in relation to your use of the App and troubleshooting;
f. all of the information listed in paragraphs 3 and 4 will be used to prevent fraud or illegal activities
g. Schappit may use all of the information listed in paragraphs 3 and 4 in anonymised form for its own research and marketing purposes; and
h. to share with third parties as described in paragraph 10 below.
SECTION B – The Organisation
6. Information which is collected from an Organisation: If you are an employee or other staff member at an Organisation, Schappit will collect the following information about you from such Organisation in relation to an Organisation’s use of the App:
a. information collected from any of the Organisation’s staff if an Organisation chooses to engage with Schappit to provide the App to its users, including contact e-mail address, contact telephone numbers, contact address, and occupation of the point of contact(s);
b. information that Schappit collects from an Organisation’s website or via other authorised marketing methods including contact names, addresses, telephone numbers and e-mail addresses.
7. How the information collected from or about Organisations is used: The information about Organisation staff collected as described in paragraph 6(a) will be used by Schappit to facilitate its business communications and provide its business offerings (namely providing the App to Organisations). The information collected by Schappit as described in paragraph 6(b) will be used by Schappit to market the App to other Organisations (subject to compliance with data protection legislation) based on the Organisations that Schappit believes may be interested in having an App developed for it.
8. Ground for processing: Schappit relies on the legitimate interests processing ground to process the information collected under paragraph 6 above. It is in Schappit’s legitimate interests to collect the data under paragraph 6(a) in order to provide the App to the Organisation and under paragraph 6(b) to promote the App to Organisations. This processing does not outweigh the rights/freedoms of the data subject because it only has a minimal/low level impact on the rights of the data subject. This is because: (a) it is not particularly sensitive data; (b) in relation to the information provided under paragraph 6(a), the Organisation wants to use the App offered/provided by Schappit i.e., the Organisation voluntarily signs-up to Schappit’s App in order to obtain a benefit and Schappit uses the personal data provided to provide such App to the Organisation; and (c) in relation to the information collected under paragraph 6(b), there is always an opt-out option provided and the information displayed on an Organisation website is displayed, in part, for marketing purposes.
SECTION C – Contact with Schappit
9. Information Schappit collects and uses if you contact us or make complaints: When Schappit receives complaints by email it files any relevant document and may retain details of the complainant and other individuals identified in the complaint. Schappit will only use this information to process the complaint, improve its ongoing product offerings and to check on Schappit’s services and staff. Schappit shall retain information in relation to a complaint for 6 years after its closure, in a secure environment and access to it will be restricted on a ‘need to know’ basis.
SECTION D – Sharing and Security
10. Sharing information with third parties: Schappit will not pass information to third party advertisers for them to advertise to you (other than as described in this paragraph) and Schappit will not permit the app to be used for advertising unless the Organisation expressly requests it.
Your information (as described in paragraphs 3 and 4 and, if you are affiliated with an Organisation, under paragraph 6) will, subject to Schappit’s obligations to comply with applicable data protection legislation, be shared with the following third parties:
In relation to the data collected by Schappit under paragraph 6:
- to Schappit’s marketing company service providers in order to manage and facilitate its marketing and engagement of Organisations;
- to Schappit’s accounting software package used to facilitate payments from you;
In relation to the data collected by the Organisation and Schappit under paragraphs 3 and 4:
- having taken precautions to maintain the security of such information, the Organisation may share this information with:
i its regulator, including OFSTED;
ii. organisers of activities and events organised by the Organisation in relation to such activities or events; or
iii. its staff, governing bodies, applicable local authorities and other official bodies related to the management and functioning of the Organisation.
In relation to the data collected by Schappit under paragraph 6 and the Organisation and Schappit under paragraphs 3 and 4
d. Schappit will share the information with:
i. the operators of the mobile application stores from which the App is available to download, including Apple, Inc. and Google Play;
ii. service providers used by Schappit to facilitate the provision of the App via the operators listed in paragraph 10(d)(i) above;
iii. Dropbox which is used to store back-ups of the information provided to the service providers listed in paragraph 10(d)(ii) above;
iv. internal company service providers used to facilitate communication between Schappit’s employees via services such as Gmail and Slack;
v. Schappit’s data centre management company and web hosting partner;
vi. Schappit’s technical support ticketing system;
vii. Schappit’s third party developers;
viii. in cases where the Organisation has chosen to permit the app to be used for advertising, the Organisation’s or Schappit’s online advertising partners, to serve adverts within the App that you may see;
ix. any third party, in relation to the sale of some or all of Schappit’s business, or its assets, or as part of any business restructuring or reorganisation. Schappit will take steps with the aim of ensuring that your rights continue to be protected;
x. data aggregators and service providers as part of an analysis of user metrics or sales performance; or
xi. law enforcement agencies in compliance with law enforcement.
11. Links to third party websites and third party adverts: Neither Schappit nor the Organisation is responsible for the privacy policies and practices of other sites even if you access them using links from the App, adverts in the App or from adverts on a webpage when you are using the App. Schappit is also not responsible for your Organisation’s privacy policies and practices. You should check the policy of your Organisation and each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the App from a third party site or via a social network (e.g. Twitter, Facebook), neither Schappit nor the Organisation is responsible for the privacy policies and practices of the owners or operators of that third party site and both Schappit and the Organisation recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
12. Security, Data Retention and Transfer: Schappit has implemented technology and policies to safeguard your privacy from unauthorised access and improper use. You may also change your account settings on your social networks (e.g. Facebook) to prevent both us and third parties seeing information in relation to you. In certain instances, where Schappit engages any third party service provider as listed in paragraph 10 above, Schappit will transfer your information outside the EEA. However, Schappit has a contractual agreement in place with each third party and systems and processes in place to ensure that such transfer is deemed adequate under applicable data protection legislation. Schappit will store your information for the period for which the Organisation is a client of Schappit’s or, in the case of the information listed in paragraph 6(b), for the period of time for which Schappit considers that a marketing follow-up is regarded as being likely. If the Organisation stops being a client of Schappit’s, Schappit will delete and/or otherwise anonymise all information held about you and the Organisation within 3 months of the Organisation ceasing to engage Schappit, excepting information collected as described in paragraph 9 above.
SECTION E – Your use of the Website
14. Links to third party websites and third party adverts: Schappit is not responsible for the privacy policies and practices of other sites even if you access them using links from the Website or adverts on the Website. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Website from a third party site or via a social network (e.g. Twitter, Facebook), Schappit is not responsible for the privacy policies and practices of the owners or operators of that third party site and both Schappit and the Organisation recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
SECTION F- Cookies and Similar Technologies
b. Disabling Cookies: The use of the cookies described above improves the functionality of the App or the Website and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings on your browser, or on your device. Please note that if you do decide to disable cookies you may not be able to access some or all parts or features of the App or Website, or the App or Website may not function properly. By continuing to use the App or Website, including using social networking media functionality, you consent to the relevant cookies being set on your device.
TABLE 1 – Cookies used by the App
|Cookie Type||and Purpose|
|Performance Cookies||Schappit uses persistent cookies and session cookies to, for example, assist in the navigation around the App, to enhance your use of the App and to support graphic and video features;|
|Google Analytics||Schappit uses Google Analytics cookies to collect information about how visitors use the Website, which Schappit use to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. Google Privacy Overview|
TABLE 2 – Cookies used by the Website
|Cookie Type||and Purpose|
|Google Analytics:||Schappit uses Google Analytics cookies to collect information about how visitors use the Website, which Schappit use to help improve it. These cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited. Google Privacy Overview|
SECTION G – Contact
16. Schappit Details: If at any time you would like to contact Schappit about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at email@example.com or write to us at “Data Protection Officer, Schappit Limited, 7 Barnsbury Street, London N1 1PW”. This is Schappit’s registered address and we are a company incorporated in England and Wales with company number 09084187.
17. Schappit’s Registration with the ICO: To the extent that Schappit acts as a Data Controller for the purposes of the Data Protection Act 1998 (i.e., in relation to the Analytical Information and the information collected under paragraphs 3(d) and paragraph 6) we have notified the Information Commissioner of our role as a ‘data controller’ under the Data Protection Act 1998 with registration number ZA074234.
18. Organisation Details: In relation to the information collected about you as listed in paragraphs 3 and 4, Schappit will work together with the Organisation if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. You must contact the Organisation (via the contact details provided on the App) to indicate your wish to exercise any of the foregoing rights. If you are a staff member or otherwise affiliated with a Organisation and therefore we hold information about you as listed in paragraph 6, you may contact Schappit as indicated in paragraph 16 at any time if you wish to exercise any of the foregoing rights.