TimeWatch app
1. Introduction
1.1 We are committed to safeguarding the privacy of the users of our application.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to Philip Crothers.
1.4 In this policy, "the application", "our application" and "TimeWatch" refer to the TimeWatch application.
For this website's privacy policy, see the bottom of the page.
2. Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process information relating to in-app purchases made using our application ("transaction data"). The transaction data may include an anonymous app user id, transaction date, expiry date, cancellation date, transaction id, product id and/or other transaction details. The sources of the transaction data are the Apple App Store, the Google Play Store and RevenueCat.
3.3 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. The source of the information will be you if you contact us, for example by email, or us if we reply to your communication.
3.4 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or other information you choose to provide to us. The source of the contact data is you.
3.5 We may process data about your use of our application and services ("usage data"). The usage data may include your IP address, geographical location, operating system, time of last use and page views as well as other information about errors that may occur in the application. The sources of the usage data are: crash log data from the Apple App Store and/or Google Play Store; purchase history from the Apple App Store, Google Play Store and/or RevenueCat.
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations - We may process your personal data for the purposes of the fulfilment of purchases, providing our services and providing our application's features. The legal basis for this processing is our legitimate interests, namely the proper administration of our application, services and business.
4.3 Relationships and communications - We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our application users, service users, individual customers, the maintenance of relationships, and the proper administration of our application, services and business.
4.4 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our application and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our application, services and business generally.
4.5 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.6 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our application, services and business, and the protection of others.
4.7 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.8 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your transaction data will be stored on the servers of our service provider RevenueCat (https://www.revenuecat.com).
5.3 Financial transactions relating to our application and services are handled by our payment services providers, Apple, Google and RevenueCat. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices using the following links:
App Store privacy policy
Google privacy policy
RevenueCat privacy policy
5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country.
6.2 We may transfer your personal data from the European Economic Area EEA to the UK and process that personal data in the UK for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3 Our service provider, RevenueCat, is based in the United States. Due to the absence of an adequacy determination with respect to the data protection laws of this country, these transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from here
See also RevenueCat Data Processing Addendum: https://www.revenuecat.com/dpa
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) contact data will be retained during any period in which it is needed for the purpose of your communication with us (for example a technical support query) and at least until we are reasonably satisfied that the purpose of the communication is completed and that the information is no longer useful for any related issue or query from you that may arise in future.
(b) communication data will be retained during any period in which it is needed for the purpose of your communication with us (for example a technical support query) and at least until we are reasonably satisfied that the purpose of the communication is completed and that the information is no longer useful for any related issue or query from you that may arise in future.
(c) transaction data will be retained during any period in which you are using our products and services. We may have access to this data for at least as long as our service providers (Google, Apple, RevenueCat) retain this data on their systems.
(d) usage data will be retained during any period in which you are using our products and services. We may have access to usage data for at least as long as our service providers (Google, Apple, RevenueCat) retain this data on their systems.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting here and here.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. Amendments
9.1 We may update this policy from time to time by publishing a new version of this page.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10. Our details
10.1 The application is owned and operated by Philip Crothers.
10.2 You can contact us by email, using the contact link on this website.