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Privacy policy
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                        App Bang Wallop Ltd Privacy Policy
This is the privacy notice of App Bang Wallop Ltd. In this document, "we", "our", or "us" refer to App
Bang Wallop Ltd

We are company number 12161414 registered in England & Wales

Our registered office is The Carriage House, Mill Street, Maidstone, Kent, UK, ME15 6YE.

Last updated: 4 Feb 2020.

Introduction

This privacy notice aims to inform you about how we collect and process any information that we
collect from you, or that you provide to us. It covers information that could identify you (“personal
information”) and information that could not. In the context of the law and this notice, “process” means
collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and
how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our
policy is not just an exercise in complying with the law, but a continuation of our respect for you and
your personal information.

We undertake to preserve the confidentiality of all information you provide to us, and hope that you
reciprocate.

Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General
Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regard to the processing
and control of your personal data. We do this now, by requesting that you read the information
provided at http://www.knowyourprivacyrights.org

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected
through our website.

1.      Data Protection Officer

        We have appointed a data protection officer (DPO) who is responsible for ensuring that our
        policy is followed.

        If you have any questions about this privacy notice, including any requests to exercise your
        legal rights, please contact our DPO at dataprotection@appbangwallop.com

2.      Data we process

        We may collect, use, store and transfer different kinds of personal data about you. We have
        collated these into groups as follows:

        Your identity includes information such as first name, last name, title, date of birth, and other
        identifiers that you may have provided at some time.

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        Your contact information includes information such as billing address, delivery address, email
        address, telephone numbers and any other information you have given to us for the purpose
        of communication or meeting.

        Your financial data includes information such as your bank account and payment card details.

        Transaction data includes details about payments or communications to and from you and
        information about products and services you have purchased from us.

        Technical data includes your internet protocol (IP) address, browser type and version, time
        zone setting and location, browser plug-in types and versions, operating system and platform
        and other technology on the devices you use to access this website.

        Your profile includes information such as your username and password, purchases or orders
        made by you, your interests, preferences, feedback and survey responses.

        Marketing data includes your preferences in receiving marketing from us; communication
        preferences; responses and actions in relation to your use of our services.

        We may aggregate anonymous data such as statistical or demographic data for any purpose.
        Anonymous data is data that does not identify you as an individual. Aggregated data may be
        derived from your personal data but is not considered personal information in law because it
        does not reveal your identity.

        For example, we may aggregate profile data to assess interest in a product or service.

        However, if we combine or connect aggregated data with your personal information so that it
        can identify you in any way, we treat the combined data as personal information and it will be
        used in accordance with this privacy notice.

3.      Special personal information

        Special personal information is data about your race or ethnicity, religious or philosophical
        beliefs, sex life, sexual orientation, political opinions, trade union membership, information
        about your health and genetic and biometric data.

        It also includes information about criminal convictions and offences.

        We do not collect any special personal information about you.

4.      If you do not provide personal information we need

        Where we need to collect personal data by law, or under the terms of a contract we have with
        you, and you fail to provide that data when requested, we may not be able to perform that
        contract. In that case, we may have to stop providing a service to you. If so, we will notify you
        of this at the time.

The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of
your personal information, and to notify you of the basis for each category.

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If a basis on which we process your personal information is no longer relevant then we shall
immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis
under which we have determined that we can continue to process your information.

5.      Information we process because we have a contractual obligation with you

        When you buy a product or service from us, or otherwise agree to our terms and conditions, a
        contract is formed between you and us.

        In order to carry out our obligations under that contract we must process the information you
        give us. Some of this information may be personal information.

        We may use it in order to:

        •       verify your identity for security purposes

        •       sell products to you

        •       provide you with our services

        •       provide you with suggestions and advice on products, services and how to obtain the
                most from using our website

        We process this information on the basis there is a contract between us, or that you have
        requested we use the information before we enter into a legal contract.

        We shall continue to process this information until the contract between us ends or is
        terminated by either party under the terms of the contract.

6.      Information we process with your consent

        Through certain actions when otherwise there is no contractual relationship between us, such
        as when you browse our website or ask us to provide you more information about our
        business, including our products and services, you provide your consent to us to process
        information that may be personal information.

        Wherever possible, we aim to obtain your explicit consent to process this information, for
        example, seeking consent to use cookies on our website.

        If you have given us explicit permission to do so, we may from time to time pass your name
        and contact information to selected associates whom we consider may provide services or
        products you would find useful.

        We continue to process your information on this basis until you withdraw your consent or it
        can be reasonably assumed that your consent no longer exists.

        You may withdraw your consent at any time by instructing us
        dataprotection@appbangwallop.com. However, if you do so, you may not be able to use our
        website or our services further.

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7.   Information we process for the purposes of legitimate interests

     We may process information on the basis there is a legitimate interest, either to you or to us,
     of doing so.

     Where we process your information on this basis, we do after having given careful
     consideration to:

     •       whether the same objective could be achieved through other means

     •       whether processing (or not processing) might cause you harm

     •       whether you would expect us to process your data, and whether you would, in the
             round, consider it reasonable to do so

     For example, we may process your data on this basis for the purposes of:

     •       record-keeping for the proper and necessary administration of our business

     •       responding to unsolicited communication from you to which we believe you would
             expect a response

     •       protecting and asserting the legal rights of any party

     •       insuring against or obtaining professional advice that is required to manage risk

     •       protecting your interests where we believe we have a duty to do so

8.   Information we process because we have a legal obligation

     Sometimes, we must process your information in order to comply with a statutory obligation.

     For example, we may be required to give information to legal authorities if they so request or
     if they have the proper authorisation such as a search warrant or court order.

     This may include your personal information.

Specific uses of information you provide to us

9.   Complaints regarding content on our website

     If you complain about any of the content on our website, we shall investigate your complaint.

     If we feel it is justified or if we believe the law requires us to do so, we shall remove the
     content while we investigate.

     Free speech is a fundamental right, so we have to make a judgment as to whose right will be
     obstructed: yours, or that of the person who posted the content that offends you.

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      If we think your complaint is vexatious or without any basis, we shall not correspond with you
      about it.

10.   Information relating to your method of payment

      We may store information about your debit or credit card or other means of payment when
      you first provide it to us.

      We store this payment information, at your request, in order to make repeat purchasing of
      goods and services easier next time you visit our website.

      We also store it to help us prevent fraud.

      We take the following measures to protect your payment information:

      •       We keep your payment information encrypted on our servers.

      •       We do not keep all your payment information so as:

              a)        to prevent the possibility of our duplicating a transaction without a new
                        instruction from you;

              b)        to prevent any other third party from carrying out a transaction without your
                        consent

      •       Access to your payment information is restricted to authorised staff only.

      •       If we ask you questions about your payment information, we only show partial detail
              OR the first four OR the last four digits of the debit or credit card number, so that you
              can identify the means of payment to which we refer.

      We automatically delete your payment information when a credit or debit card expires.

11.   Information about your direct debit

      When you agree to set up a direct debit arrangement, the information you give to us is
      passed to our own bank HSBC for processing according to our instructions. We do not keep a
      copy.

      We are registered under the direct debit guarantee scheme. This provides for the customer's
      bank to refund disputed payments without question, pending further investigation. Direct
      debits can only be set up for payments to beneficiaries that are approved originators of direct
      debits. In order to be approved, these beneficiaries are subjected to careful vetting
      procedures. Once approved, they are required to give indemnity guarantees through their
      banks.

12.   Job application and employment

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      If you send us information in connection with a job application, we may keep it for up to three
      years in case we decide to contact you at a later date.

      If we employ you, we collect information about you and your work from time to time
      throughout the period of your employment. This information will be used only for purposes
      directly relevant to your employment. After your employment has ended, we will keep your file
      for six years before destroying or deleting it.

13.   Communicating with us

      When you contact us, whether by telephone, through our website or by e-mail, we collect the
      data you have given to us in order to reply with the information you need.

      We record your request and our reply in order to increase the efficiency of our business.

      We keep personally identifiable information associated with your message, such as your
      name and email address so as to be able to track our communications with you to provide a
      high quality service.

14.   Complaining

      When we receive a complaint, we record all the information you have given to us.

      We use that information to resolve your complaint.

      If your complaint reasonably requires us to contact some other person, we may decide to give
      to that other person some of the information contained in your complaint. We do this as
      infrequently as possible, but it is a matter for our sole discretion as to whether we do give
      information, and if we do, what that information is.

      We may also compile statistics showing information obtained from this source to assess the
      level of service we provide, but not in a way that could identify you or any other person.

15.   Affiliate and business partner information

      This is information given to us by you in your capacity as an affiliate of us or as a business
      partner.

      It allows us to recognise visitors that you have referred to us, and to credit to you commission
      due for such referrals. It also includes information that allows us to transfer commission to
      you.

      The information is not used for any other purpose.

      We undertake to preserve the confidentiality of the information and of the terms of our
      relationship.

      We expect any affiliate or partner to agree to reciprocate this policy.

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Use of information we collect through automated systems when
you visit our website

16.    Cookies

       Cookies are small text files that are placed on your computer's hard drive by your web
       browser when you visit any website. They allow information gathered on one web page to be
       stored until it is needed for use on another, allowing a website to provide you with a
       personalised experience and the website owner with statistics about how you use the website
       so that it can be improved.

       Some cookies may last for a defined period of time, such as one day or until you close your
       browser. Others last indefinitely. Your web browser should allow you to delete any you
       choose. It also should allow you to prevent or limit their use.

       Our website does not currently use cookies.

17.    Personal identifiers from your browsing activity

       Requests by your web browser to our servers for web pages and other content on our
       website are recorded.

       We record information such as your geographical location, your Internet service provider and
       your IP address. We also record information about the software you are using to browse our
       website, such as the type of computer or device and the screen resolution.

       We use this information in aggregate to assess the popularity of the webpages on our website
       and how we perform in providing content to you.

       If combined with other information we know about you from previous visits, the data possibly
       could be used to identify you personally, even if you are not signed in to our website.

18.    Our use of re-marketing

       Re-marketing involves placing a cookie on your computer when you browse our website in
       order to be able to serve to you an advert for our products or services when you visit some
       other website.

       We may use a third party to provide us with re-marketing services from time to time. If so, and
       only if cookie consent has been received, you may see advertisements for our products and
       services on other websites.

Disclosure and sharing of your information

19.    Information we obtain from third parties

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      Although we do not disclose your personal information to any third party (except as set out in
      this notice), we sometimes receive data that is indirectly made up from your personal
      information from third parties whose services we use.

20.   Third party advertising on our website

      Third parties may advertise on our website. In doing so, those parties, their agents or other
      companies working for them may use technology that automatically collects information about
      you when their advertisement is displayed on our website.

      They may also use other technology such as cookies or JavaScript to personalise the content
      of, and to measure the performance of their adverts.

      We do not have control over these technologies or the data that these parties obtain.
      Accordingly, this privacy notice does not cover the information practices of these third parties.

21.   Credit reference

      To assist in combating fraud, we share information with credit reference agencies, so far as it
      relates to clients or customers who instruct their credit card issuer to cancel payment to us
      without having first provided an acceptable reason to us and given us the opportunity to
      refund their money.

22.   Data may be processed outside the European Union

      Our website is hosted in the UK

      We may also use outsourced services in countries outside of the UK and the European Union
      from time to time in other aspects of our business.

      Accordingly data obtained within the UK or any other country could be processed outside the
      European Union.

      For example, some of the software our website uses may have been developed in the United
      States of America or in Australia.

      We use the following safeguards with respect to data transferred outside the European Union:

      •       the processor is within the same corporate group as our business or organisation and
              abides by the same binding corporate rules regarding data processing.

      •       the data protection clauses in our contracts with data processors include transfer
              clauses written by or approved by a supervisory authority in the UK

      •       we comply with a code of conduct approved by a supervisory authority in the UK

      •       we are certified under an approved certification mechanism as provided for in the Act.

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      •       both our organisation and the processor are public authorities between whom there is
              either a legally binding agreement or administrative arrangements approved by a
              supervisory authority in the UK relating to protection of your information.

Control over your own information

23.   Your duty to inform us of changes

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

24.   Access to your personal information

      To obtain a copy of any personally identifiable information that we hold about you, you should
      contact us to make that request.

      After receiving the request, we will tell you when we expect to provide you with the
      information, and whether we require any fee for providing it to you.

25.   Removal of your information

      If you wish us to remove personally identifiable information from our website or internal
      business systems, you should contact us to make your request.

      This may limit the service we can provide to you.

26.   Verification of your information

      When we receive any request to access, edit or delete personal identifiable information we
      shall first take reasonable steps to verify your identity before granting you access or otherwise
      taking any action. This is important to safeguard your information.

Other matters

27.   Use of site by children

      We do not sell products or provide services for purchase by children, nor do we market to
      children.

      If you are under 18, you may use our website only with consent from a parent or guardian

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28.   Encryption of data sent between us

      We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to
      encrypt any data you give us.

      Whenever information is transferred between us, you can check that it is done so using SSL
      by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or
      toolbar.

29.   How you can complain

      If you are not happy with our privacy policy or if you have any complaint then you should tell
      us.

      If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in
      good faith with us in a process of mediation or arbitration.

      If you are in any way dissatisfied about how we process your personal information, you have
      a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be
      done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity
      to talk to you about your concern before you approach the ICO.

30.   Retention period for personal data

      Except as otherwise mentioned in this privacy notice, we keep your personal information only
      for as long as required by us:

      •       to provide you with the services you have requested;

      •       to comply with other law, including for the period demanded by our tax authorities;

      •       to support a claim or defence in court.

31.   Compliance with the law

      Our privacy policy has been compiled so as to comply with the law of every country or legal
      jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your
      jurisdiction, we should like to hear from you.

      However, ultimately it is your choice as to whether you wish to use our website.

32.   Review of this privacy policy

      We may update this privacy notice from time to time as necessary. The terms that apply to
      you are those posted here on our website on the day you use our website. We advise you to
      print a copy for your records.

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If you have any question regarding our privacy policy, please contact us at
dataprotection@appbangwallop.com

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