CONSENT TO UMII’S PRIVACY POLICY

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our privacy policy and it is important that you read that information.

By using this App, you consent to our processing of your personal data (including your name, contact details and device information) as described in this policy.

How you can withdraw consent

You may change your mind and withdraw consent at any time by deleting your account, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

UMII’S PRIVACY POLICY

Welcome to the Umii Privacy Policy (the “Policy”).

We respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data when you use:

the Umii [version 1.0.3 and above] mobile application software (the “App”) [available on the Apple App Store and the Google Play Store], once you have downloaded the App onto your mobile telephone or handheld device (the “Device”); and
any of the services accessible through the App (the “Services”) that are available on the App Site or other sites of ours (the “Services Sites”).
The Umii Website (https://umii.app/)

It is important that you read this Policy together with our Terms and Conditions of Use and our End User Licence Agreement (“EULA”).

By downloading and installing our App, you agree that we can collect, transfer, store, disclose and use your information as described in this Policy.

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.

This App is not intended for those under the age of 16 and we do not knowingly collect data relating to those under the age of 16.

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

Who We Are

We are the controller and are responsible for your personal data. If you have any questions about this Policy, please contact us using the following details:

Full name of legal entity: Umii Technologies LTD (CRN: 10839796)
Name: Georgia Wheadon
Email address: Georgia@umii.app
Postal address: Hollinwood Business Centre, Albert Street, Oldham, England, OL8 3QL

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

The Data We Collect About You

When you download the App, we may collect, store, use and transfer certain information about you, such as:

Identity Data: name, username, age, university of study, university course, photographs;
Contact Data: email address
Profile Data: includes username and passwords, interests, preferences, feedback and survey responses;
Usage Data: includes details of the App or visits to our website including, but not limited to, traffic data and other communications data, IP address, browser type, referring domain, pages visited, access times, mobile carrier, search terms, advertisements and interactions with us;
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences;
Content Data: Any content including text, images or videos uploaded into the application;
Device and Technical Data: includes IP address, the type of mobile device you use, a unique device identifier, device model, your mobile operating system, MAC address, the type of mobile browser you use, time zone setting;

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us at consent@umii.app

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

PURPOSE/ACTIVITY	TYPE OF DATA	LAWFUL BASIS FOR PROCESSING
To install the App and register you as a new App user	Identity Contact Profile Content Marketing and Communications Device and Technical	Consent
To facilitate you with networking opportunities when using the App	Profile Identity	Consent
To keep records of complaints made by you about other users of the App and about you by other users of the App	Identity Profile Contact	Necessary for our and your legitimate interests (to ensure user security and maintain user experience)
To verify your identity, prevent abuse of the App and to ensure safety and security	Contact	Necessary for our legitimate interests (to prevent fraud and to safeguard all users of the App)
To manage our relationship with you including notifying you of changes to the App and new offerings, providing support when you contact our Customer Support team	Identity Contact Profile Marketing and Communications	Consent Performance of a contract with you To keep records updated and to analyse how customers use our App and to troubleshoot problems) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Consent Performance of a contract with you To analyse how customers use the App and to develop it and grow our business)
To administer protect and grow our business, App and network security including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our and your legitimate interests (to ensure user security and maintain user experience)
To share data with your university	Identity Contact Device Content Profile Usage Marketing and Communications	Necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. To enable universities to understand its student demographic, with the ultimate aim of improving and promoting student wellbeing.
To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our App and grow our business)
Sharing data to third parties when you use a third party web client or application to access your account, for the monitoring of activity on the App and approval of content, to cooperate with legal obligations.	Identity Contact Profile	Consent Necessary for compliance with legal obligations

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

It is not compulsory for you to provide any special categories of personal data about yourself, however you may opt to complete a questionnaire which captures special category personal data to be shared with universities on an anonymous basis. We do not require you to provide any information about criminal convictions and offences. However, we will seek to obtain your explicit consent when you register and create your profile if you wish to provide us with special categories of personal data at this stage. While you may provide this information to us, you are not required to provide this information. You may, however, provide this information during your use of the App. Where you do provide such sensitive data, you are explicitly consenting to our processing of your information. We do not recommend that you disclose this information to others when using the App.

Additional Information

We may ask you to provide information as to why you use the app. This information may be shared with third parties for purposes relating to, for example, our partnerships with your university. The information shared will be anonymous. We may also collect additional information in connection with your use of the App, for example, a university may want to know how many of their students start conversations with one another. This does not include messages exchanged between the App users. The information shared will also be anonymous.

Cookies

We collect cookies on our website (https://umii.app/) to distinguish you from other users and to remember your preferences. This helps us to provide you with a good experience when you use the site and also allows us to improve the site. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookies policy.

Data Storage and Retention

We do not transfer your personal data outside the European Economic Area (“EEA”). Data is stored within the UK and Ireland.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

Where you request that your profile is deleted via the app, it is immediately made unavailable and deleted within 30 days. Correspondence with our Customer Support team via info@umii.app will be retained for longer to allow us to deal with any subsequent queries you may have but will usually be deleted within 6 years if there are no queries.

In compliance with legal obligations, information such as IP addresses, mobile numbers and email addresses are retained for anti-fraud and anti-spam purposes for as long as they are relevant.

In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.

DISCLOSURE OF INFORMATION

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

External Third Parties: Service providers, professional advisers, HM Revenue and Customs, regulators and other authorities, market researchers, fraud prevention agencies, and our development agency;
Specific third parties:
- Amplitude – We use Amplitude on the app to collect usage data including the number of connections made, number of messages set, number of profile views etc;
- Nova (our development agency); and
- Our UK Higher Education Partnerships
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

WHAT OTHERS MAY SEE ABOUT YOU

When using Umii, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by users of the App and non-users of the App. Access to the app is only available to users with an account and profile. However, users may take screenshots of any viewable information within the App and share this through external channels.

DEACTIVATING YOUR ACCOUNT

You may access or modify your information you provided at any time or permanently delete your account.

After you have deactivated your account your profile will be deleted. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your account. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others during this period.

CHANGES TO THIS POLICY

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will be available at Umii.app/privacy/. If we make a material change to this Policy, we will notify you via the App or email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

SECURITY

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those parties who are subject to confidentiality obligations and have a business need to know.

We will collect and store personal data on your mobile device using application data caches and browser web storage (including HTML5) and other technology. Ensure when using messenger and creating your profile, you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

YOUR RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

Right to be informed: what personal data an organisation is processing and why (this notice).
Right of access: you can receive a copy of the data we hold about you (also known as a “data subject access request”).
Right of rectification: if the data held is inaccurate or incomplete, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted where there is no good reason for us to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to restrict processing: in limited circumstances, you have the right to request that processing is suspended but the data retained.
Right to data portability: you can request a copy of your data in a machine-readable form to be transferred to you or a third party.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Right to withdraw consent: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Rights related to automated decision making including profiling: Data subjects have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on the data subject.

EFFECTIVE DATE

This Privacy Policy was last updated on 05/01/2020.