Aglet

Privacy Notice

Effective date: 1 March 2020

Last Updated: 31 March 2023

We are Onlife Limited and trade as “Aglet”. Our company number is 11457733 and our registered address is Suite LP44627 20-22 Wenlock Road, London, England, N1 7GU.

We take the privacy of your information very seriously. This notice is designed to tell you about our practices, as data controller, regarding the collection, use and disclosure of personal data which may be obtained by us via our App, website or collected through other means such as by an online form or email. For the avoidance of doubt, this notice does not cover any information which is anonymised and cannot be used to identify a living individual.

This notice applies to personal data held and processed by us relating to our users whether they are using our App or simply browsing the website and any third party suppliers whose data we process, but does not apply to information we hold in relation to our staff and contractors. In this notice “you” refers to any individual whose personal data we hold or process.

This privacy notice is governed by the EU General Data Protection Regulation (the “GDPR”), the Data Protection Act 2018 and any other applicable data or privacy legislation. This notice may be updated from time to time and you should check this page regularly for any updates. Changes to this notice are effective when they are posted on this page.

Unless otherwise defined in this notice, terms used in this notice have the same meanings as in our App Terms of Use.

Personal data we collect and how we process this data

We will generally collect information from you directly, such as when you register your account on the App. We may also collect information from a third party or from you indirectly as a result of your interaction with our software, such as through the use of cookies.

If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.

Below we have set out the categories of data we collect, the legal basis we rely on to process the data and how we process the data:

Personal Data & Legal Basis

We may collect and process the following categories of personal data:

log-in details and information you provide when setting up an account with us on our App or website, such as your name and email address and other information you input while signed into your account with us (“Account Information”).

We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
contact information we collect from you (for example your name, address, telephone number, email address) (“Contact Information”);

We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
A record of any correspondence or communication between you and us (“Communication Information”).

We process this information when we monitor our relationship with you and provide services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to you.
If you are a user of the App, we collect location information about your device, including tracking step-count data, during gameplay as well as in the background when you are not directly interacting with the services on the App (“Location Information”). Once you delete your account on the App, such information is anonymised and no longer constitutes personal data.

We use Location Information to verify your steps and movement history during gameplay and as part of the overall gameplay experience. We may also use the information to log when you go to certain specific locations that are part of the game.

We process Location Information on the basis that you have consented to this and you may change your mind at any time by turning off location tracking either in your device settings or the app’s settings.
Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a payment processor or marketing software provider) (“Third Party Contact Information”).

We process this information as part of the provision of our services to our users on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our services to our users.
Cookie Information. A cookie is a small text file which asks permission to be placed on your computer’s hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

Where applicable and necessary, we process Cookie Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests.
Information relating to user generated content which may contain personal data and which are generated or transmitted, whether publicly or privately, to or through the App or website, such as when a user posts a comment or review (“User Generated Information”).

Please note that User Generated Information will include images, video, audio and text which you post to the App. We may use this information to display and share comments, images, video, audio, text and other User Generated Information information to other users of the App in accordance with your preferences on the basis of our legitimate interest in providing our services to our users.
Marketing information. We may hold information about you in order to provide you with information about our services or other third party services which may of interest to you (for instance because you have frequented those brands or stores during gameplay). This information may include your name, email address, phone number, address, and other information (“Marketing Information”).

We process this information on the basis that you have consented to receiving the information.

In addition to the lawful bases of processing set out above, processing may also be necessary for the compliance of a legal obligation to which we are subject.

When you make an in-App purchase via the Apple AppStore (iOS) or Google PlayStore (Android), we do not collect or otherwise process any credit card, debit card or other payment related information. For information on how such personal data is processed, please refer to the relevant app-store provider’s privacy policies.

Data Retention

Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:

Category of Personal data
Length of retention
Account Information & Location Information
Until such time as your account remains open with us and up to 30 days following the date your account is terminated.
Contact Information & Communication Information

Following an enquiry with us and provided you have not set up an account with us, we will remove your Contact Information and Communication Information from our system after a period of 1 year unless you subsequently become a user of our App or otherwise enter into a contract with us.

Cookie Information

1 year.

Personal data processed in relation to a contract between you and us

7 years from either the end of our contract or the date you last used our App.

Marketing Information

1 year from the last date on which you have interacted with us.

For any category of personal data not specifically defined in this section or notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.

If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.

Sharing your information

We may disclose personal data to third parties in the following circumstances:

If you are a user of the App, your in-game profile (including details such as your username), in-game scores, achievements and User Generated Information (including user generated images, audio, video and text) will be visible to other users of the App. You may also have the option and choose to connect the App’s gaming services with a third party network (such as Instagram) in which case your in-game profile will be visible to other users of such third party network.
Information which is publicly available on the App, including User Generated Information, may be shared with users who receive our services outside of the EEA.
If you are a user of the App, we may share your personal data with our third party partners for their direct marketing purposes (for instance because you have frequented those brands or stores during gameplay and as a result they may be of interest to you), but only to the extent you have consented to this.
We may work with other professionals and providers in providing and delivering our services to you - this may include a marketing software provider or website management provider.
We may disclose information to our group companies.
If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
In order to enforce any terms and conditions or agreements for our services that may apply.
As part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
To protect our rights, property and safety, or the rights, property and safety of our users or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If we do supply your personal data to a third party we will take steps to ensure that your privacy rights are protected and that such third party complies with the terms of this notice.

We may also share anonymised data with third parties for market analytical purposes.

Cookies and IP Address

Like most websites and apps, we use cookies to help provide you with the best experience whilst using our service. The cookies we use are split between the following categories:

Strictly necessary cookies - which are an essential part of our service and affect the way you can use our website (e.g. security & authentication)
Performance cookies - which are used for analytics (e.g. understanding usage on our website)
Functionality cookies - which collect information about your device to help you customize our service (e.g. remembering your username, language, time zone settings or accessing inline help)
Google Analytics; Mixpanel; Intercom.

On your first visit to our website from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for Strictly Necessary Cookies, until you have provided your consent by clicking the “Accept” button. If you click the “Accept” button on our cookies notice, Performance and Functionality cookies will also be loaded.

Below is a list of the cookies currently set by us:

Google Analytics
Mixpanel
Intercom

As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.

Refusing Cookies

You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.

IP Address

An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.

Security

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):

protecting our servers by both hardware and software firewalls;
locating our data processing storage facilities in secure locations;
encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
when necessary, disposing of or deleting your data so it is done so securely;
regularly backing up and encrypting all data we hold.

We will ensure that our staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.

This notice and our procedures for handling personal data will be reviewed as necessary.

Third party links

Our website may contain links to other sites that are not operated by us. This notice applies to our services only so if you click on a third-party link, we strongly advise you to review that site’s privacy policy.

We have no control over and are not responsible or liable for the content, privacy policies or practices of any third-party sites or services.

Your privacy rights

With respect to your personal data, you have:

The right to be informed
You have a right to know about our personal data protection and processing activities, details of which are contained in this notice.
The right to withdraw consent

If we are relying on your consent as the basis on which we are processing your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before your withdrawal.

The right of access

If you have registered an account with us, you can access certain information of yours by logging into your account. You can also make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (this is free of charge, except that we may charge you a reasonable fee in the event of a repeat or complex request). If you wish to make a SAR please contact us using the details below.

The right to rectification

If you have registered an account with us, you can rectify certain personal data provided to us by logging into your account.

Otherwise, please inform us if information we hold about you is incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.

We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.

The right to erasure (the ‘right to be forgotten’)

If you have registered an account with us, you have the right to delete your account at any time.

Please notify us if you no longer wish for us to hold personal data about you (although in practice, we will be unable to provide our services to you without holding your personal data). Unless we have reasonable grounds to refuse the request for erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup systems or by way of a suppression list, but we will take steps to ensure that it will not be accessible.

We will communicate the erasure to any third parties to whom we have passed your information.

The right to restrict processing

You can request that we no longer process your personal data in certain ways, although this may affect our ability to provide our services to you.

The right to data portability

You have the right to receive copies of personal data we hold about you in a commonly used and easily storable format (please let us know a format which suits you). You may also request that we transfer your personal data directly to third party (where technically possible).

The right to object

Unless we have overriding legitimate grounds for such processing, you may object to us using your personal data if you feel your fundamental rights and freedoms are impacted.

You may also object if we use your personal data for direct marketing purposes (including profiling) or for research or statistical purposes.

Please notify your objection to us and we will gladly cease such processing, unless we have overriding legitimate grounds or it is otherwise permitted under applicable law.

Rights with respect to automated decision-making and profiling

You have a right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you. You are not entitled to this right when the automated processing is necessary for us to perform our obligations under a contract with you, when it is permitted by law, or if you have given your explicit consent.

All SARs and other requests or notifications in respect of your above rights must be sent to us in writing via our contact page at contact@aglet.app or by post to Onlife Limited, Suite Lp44627 20-22 Wenlock Road, London, England, N1 7GU.

We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

Data breaches

If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the Information Commissioner’s Office (ICO) (as necessary).

If a breach is likely to result in a risk to your data rights and freedoms, we will notify you as soon as possible.

Transferring your information outside the EEA

Your personal data may be transferred and stored in a country that is based outside of the UK or European Economic Area (together the EEA), particularly if you are a resident in the United States of America. In particular:

Some of our data processors (including third party payment processors or server providers), are based outside of the EEA, e.g. in the USA. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services or communicate with you.
We may communicate with individuals or organisations outside of the EEA in providing our services. Those communications may include personal data (such as contact information).
From time to time your information may be stored in devices which are used by our staff who are outside of the EEA, such as in the US or Australia (but staff will be subject to our cyber-security policies).

If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this notice.

Contact us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal data or how it is handled, you can do so via our contact page at contact@aglet.app or by post to Onlife Limited, Suite Lp44627 20-22 Wenlock Road, London, England, N1 7GU.

Complaints

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office by visiting http://www.ico.org.uk/ for further assistance.