PRIVACY POLICY

Squalk Ltd ("we") are committed to protecting and respecting your privacy.

SCOPE OF POLICY

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


Squalk mobile application software ("App") available on our site or hosted on the Apple App Store ("App Site"), or from the Google play store once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device ("Device").

Any of the services accessible through the App ("Services") that are available on the App Site or other sites of ours ("Services Sites"), unless the EULA states that a separate privacy policy applies to a particular service, in which case that privacy policy only applies.

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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom from time to time., the data controller is Bell Innovation Limited (company number: 05469863) whose registered office is at 1 London Road, Southampton, Hampshire SO15 2AE.


INFORMATION WE COLLECT FROM YOU

We will collect and process the following data about you:


Information you give us (Submitted information):

  • On registration, your phone number
  • Your photo and buddy name within our chat function

Information our system reads out (Synchronization information):
  • The SQUALK app needs to access your phone contacts and sync your numbers with our servers in order to connect you with other SQUALK users you already know. The SQUALK app will only read and store phone numbers, not the names or any other data. After syncing all data will be deleted. At no time do our servers store your numbers into our database. Your data is only buffered for a second or two during the sync.

Device information:

  • technical information, including 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) and mobile network information.


The provision of certain of your personal information is required from you to enable us to provide our Services to you. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

Please note that as part of the functionality of the App, our logo will appear within the address book of your phone, providing you with a short cut to making calls via the App.

We will hold your personal information for a period of 1 year after you have had zero credit on your account or you ask us to close your account.

You are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
 

SHARING OF INFORMATION AND TRANSFER OUTSIDE THE EEA

We do not share your personal information with other third parties. 

The App is hosted on servers outside of the EEA depending on your geographical location, however we have ensured that necessary protections are in place to protect your data - for example, that such hosting companies are signed up to the EU-US Privacy Shield Framework. Otherwise, to the best of our knowledge, understanding and belief your information will not be transferred outside of the EEA or to any country not approved by the European Commission.

Reasons we can collect and use your personal information

We rely on the following grounds as the lawful basis on which we collect and use your personal data:

  • The processing is necessary for the performance of the contract between us in relation to provision of App; and
  • The processing is necessary for achieving our legitimate business interests.

Under the data protections laws, you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
  • require us to correct any mistakes in your information which we hold
  • require the erasure of personal information concerning you in certain situations
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
  • object at any time to processing of personal information concerning you for direct marketing
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
  • object in certain other situations to our continued processing of your personal information
  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • use our chat function, call or write to us using the contract details set out below;
  • let us have enough information to identify you i.e. your phone number and/or buddy name; and
  • let us know the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.


How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The data protection laws also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.


Changes to this privacy notice

This privacy notice was last updated 25th March 2020.
We may change this privacy notice from time to time and will keep you updated of any changes we make.


How to contact us

If you have any questions about this privacy notice or the information we hold about you please contact us using our chat function or write to us at 1 London Road, Southampton, Hampshire SO15 2AE.