Privacy Policy - Student Safety

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy describes how we will collect, use, share and otherwise process your personal data in connection with your use of:
The Student Safety App mobile application software (the “App”).
Any of our services that are accessible through the App or on our website at: https://studentsafetyapp.com/ (the “Services”).

This App is not intended for children, and we do not knowingly collect data relating to children.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
Cayson Global Ltd is the data controller and is responsible for your personal data (collectively referred to as “Cayson Global”, “we”, “us” or “our” in this Privacy Policy). This means that we are responsible for deciding how we hold and use personal data about you.

If you have any questions about this Privacy Policy, please contact us using the details set out below:

Cayson Global Ltd
Address: C/O Mercury Hamlin & Associates FZ-LLC, Office 904, JBC 4, Cluster N, Jumeriah Lake Towers, PO Box No. 336618, UAE
Email Address: support@studentsafetyapp.com

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 (www.ico.org.uk) or country-specific equivalent body. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our Privacy Policy under regular review.
It may change and, if it does, those changes will be posted on this page and notified to you by push notification when you next start the App or log onto your Profile.
You may from time to time be required to read and acknowledge the changes to continue your use of the App or the Services.
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.
Please visit your Account to update your details.

THIRD PARTY LINKS AND SITES

Our App and Services may, from time to time, contain links to and from the websites of third parties, such as Birmingham City Council and the Student Safety Council (“Third Parties”). Please note that these websites (and any services accessible through them) are controlled by those Third Parties and are not covered by this Privacy Policy.
You should review the relevant Third Party privacy notices to understand how the relevant Third Party uses your personal data before you submit any personal data to these websites or use these services.

The data we collect about you.

We collect, use, store and transfer different kinds of personal data about you. To make it easier for you to use this Privacy Policy, we group these into the following categories. Each of these categories is described in more detail below.

Type of Personal Data	Details
Identity Data	First name, last name, title, date of birth and Profile Data.
Contact Data	First name, last name, contact address, email address and telephone numbers, your communication preferences and copies of the communications between you and us.
Profile Data	Your email address, username and password.
Transaction Data	Billing and delivery addresses, payment card details, history of your payments, purchases, deliveries, returns and refunds and the applicable terms and conditions of your purchases.
Device Data	the type of device you use, your unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, IP address, and time zone setting.
Content Data	information that you store or generate in the App, being photos, videos and associated metadata, check-ins, posts and messages.
Usage Data	logs and detail of your use of our Apps and Services, being the dates and times on which you download, access and update the App and our Services, any error or debugging information, and the resources that you access and the actions we and you take in relation to them and Cookies Data.
Security Data	Information we collect about your use of the App, our Services and our Sites in order to ensure your and our other users’ safety and security, being Usage Data, the Cookies Data generated, and the information provided to us by our payment processing provider.
Cookies Data	The information collected through the cookies and similar technologies listed in our Cookies Notice available.
Direct Marketing Data	Your direct marketing preferences, consents for receiving direct marketing from us and/or our third parties and the history of the direct marketing communications we have sent to you.
Location Data	Your current location as disclosed by GPS technology, Wi-Fi connections, or your IP address for the time period where you have permitted us to collect it.
Connected Data	Information stored on your Device that you permit the App to connect to, being Contacts lists and login information.
Social Media Data	Your social media account information.
Feedback Data	Your feedback and survey responses.
Personalisation Data	Cookies Data, Device Data, Content Data, Transaction Data, Connected Data, Social Media Data, Usage Data, Location Data, and the preferences we have inferred you have and use to personalise the App and Services.

SPECIAL CATEGORIES OF PERSONAL DATA

We process the following special categories of personal data about you.

Purpose/Activity	Types of personal data	Lawful basis for processing
Blood Group Existing medical conditions and medication	Health Data Health Data	Consent Consent

CRIMINAL OFFENCE DATA

We do not intentionally collect criminal offence data about you. However, We may process data relating to criminal offences in monitoring the use of our App for security purposes, where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim or circumvent the security of the App or Services.

In such circumstances we will provide that information to law enforcement and/or use it to establish, exercise or defend a legal claim. In those circumstances, according to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information).

UK law authorises that processing under the Data Protection Act 2018 and although the appropriate authorisation will depend on a case-by-case basis, monitoring for criminal behaviour through the use of our App is in the Substantial public interest (preventing or detecting unlawful acts) and processing information related to suspected criminal activity for legal claims is permitted under the additional condition of legal claims authorised under applicable national law.

How is your personal data collected?

We collect your personal data in the following way:

Method of collection	Details
Registration	We collect your Identity Data and Contact Data when you register your Account with us.
Communications	When you communicate with us via email, telephone, one of our online forms or chat we collect your Contact Data. If you contact us through the App using the chat function, we also collect Device and Cookies Data to operate our chat function and respond to your messages. If the communication relates to an error or problem you are having with the App or one of our Services, we will also collect Usage Data for diagnosis and improvement.
Information you generate when using the App and Services.	Each time you access and use our App and Services we collect Content Data, Device Data, Cookies Data, Personalisation Data and Usage Data. We collect Content Data where you upload it to the App or interact with the content available on the App. We collect Device Data, Cookies Data, Personalisation Data and Usage Data by using cookies and other similar technologies. Please see our Cookies Notice available at.
Information we collect through monitoring the use of the App, our website and Services	Each time you access and use the App and Services we collect information about that access and use, being Device Data, Content Data, Cookies Data, and Usage Data.
Additional information we otherwise collect through the App, our website and Services where we have your consent to do so	Where you provide your consent, we collect your Location Data on an ongoing basis while you have the App installed on your device.
Direct Marketing	We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications, or we receive prospect information from our data broker partners.
Connected Data	We collect Connected Data when you choose to connect your connected device to your Account.
Social Media Data	We collect Social Media Data when you choose to connect your social media account to your Account.
Information we receive from third parties and publicly available sources	We will receive personal data about you from the third parties and public sources set out below: § Device Data and Cookies Data from the following parties: o analytics providers based inside and/or outside the UK; o advertising networks based inside and/or outside the UK; and o search information providers based inside and/or outside the UK; § Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services based in inside and/or outside the UK; § Identity Data, Contact Data and Direct Marketing Data from data brokers or aggregators based inside and/or outside the UK; § Identity Data and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.
Unique application numbers	When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies (small files placed on your device) and other tracking technologies on the App and in our direct marketing emails to improve your experience and our development of the App and our Services.

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 Notice available at.

How we use your personal data
We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

-Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by deleting your account via accessing the ‘settings’ section of your Account, using our Cookies Banner at: [Insert Link] or by contacting us at: support@studentsafetyapp.com.

–Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.

–Legitimate interests. 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

–Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

EXAMPLES OF HOW WE USE YOUR PERSONAL DATA

Purpose or activity	Type of personal data	Lawful basis for processing
DELIVERY AND IMPROVEMENT OF OUR APP AND PURCHASES
To permit you to install the App and register you as a new App user.	Identity Data Contact Data Financial Data Device Data	Performance of a contract. Legitimate interests (delivering our App to you).
To take steps towards providing you with services at your request, to process and fulfil in-App orders/purchases and deliver services to you, including managing payments and sending you service communications.	Identity Data Contact Data Transaction Data Device Data Location Data	Performance of a contract.
To provide you with your membership or subscription benefits.	Identity Data Contact Data Transaction Data	Performance of a contract.
Enforce our terms and conditions, including to collect money owed to us.	Identity Data	Legitimate interests (to recover debts due to us).
ACCOUNT MANAGEMENT AND PROFILING
Combining the information we collect about you into a single customer Account.	Contact Data Direct marketing Data	Legitimate Interests (to publicise and grow our business).
DIRECT MARKETING
To send you direct marketing communications via email, text and/or push notification.	Contact Data Device Data Direct Marketing	Consent. Unless we can rely on the soft opt-in and you have not opted out, in which case we rely on Legitimate Interest (to publicise and grow our business).
To send you direct marketing communications by telephone or post.	Contact Data Device Data Direct Marketing Data	Legitimate interests (to publicise and grow our business) Unless you have opted out, in which case we rely on Consent.
TROUBLESHOOTING, IMPROVEMENT AND SECURITY
To administer, monitor and improve our business, Services and this App including troubleshooting, data analysis and system testing.	Identity Data Contact Data Device Data	Legitimate interests (for running our business, provision of administration and IT services, network security, maintaining the security of our App and Services, providing a secure service to users and preventing fraudulent and other misuse of our App).
Applying security measures to our processing of your personal data, including processing in connection with the App.	All personal data under this Privacy Policy	Legal obligation (applying appropriate technical and organisational measures under Article 32 of the UK GDPR.
Otherwise monitoring use of the App and deploying appropriate security measures.	Contact Data Security Data Transaction Data	Legitimate interests (running our business, provision of administration and IT services, network security, maintaining the security of our App and services, providing a secure service to users and preventing fraudulent and other misuse of our App).
RIGHTS AND OBLIGATIONS
To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities’ requests.	All personal data under this Privacy Policy	Legal obligation.
COOKIES AND PERSONALISATION
To deploy and process personal data collected via Cookies that are strictly necessary, as set out in the Cookies Notice available at.	Cookies Data	Legitimate interests (delivering and securing the App and our Services).
To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the Cookies Notice available at.	Cookies Data	Consent.
To deliver (personalised) advertisements to you.	Personalisation	Consent.
OTHER COMMUNICATIONS
To notify you of changes to the App, Services, your purchases and our terms and conditions for ongoing contracts.	Contact Data	For ongoing or prospective contracts, Performance of a contract. Otherwise, Legitimate interests (in servicing our users and prospective users).
To respond to your requests to exercise your rights under this notice	As relevant to your request	Legal obligation (complying with data subject requests under Chapter 3 of the UK GDPR.
To enable you to participate in a prize draw or competition (where applicable, please also see the separate prize or competition privacy notice)	Contact Data Direct Marketing Data Competition Data	Legitimate interests (in growing and publicising our business). Unless you have previously opted out, where we will rely on Consent. Performance of a contract (once you have entered).
To ask you to complete a survey and process your response (where applicable, please also see the separate Privacy Policy).	Contact Data	Legitimate interests (to analyse how users use our products or Services and to develop them and grow our business). Unless you have previously opted out, where we will rely on Consent.
To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary.	As relevant to your enquiry or request	Legitimate interests (service our users and prospective users).
PERSONAL DATA SHARING
Sell personal data with our third-party providers for the purpose(s) of data analytics and direct marketing purposes.	Contact Data Direct Marketing Data Competition Data	Consent.
Share personal data with our third-party providers for purposes not otherwise set out above.	Contact Data Direct Marketing Data Competition Data	Legitimate interests (for the purpose relevant to the recipient, as set out at “Disclosures of your personal data”.
BUSINESS CONTACTS
Process personal data relating to staff members of our business contacts, including suppliers, customers and prospects.	Contact Data.	Legitimate interests (servicing and receiving products or services, to or from our business contacts and carry out our B2B business).

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Disclosures of your personal data

We may share your personal data with the following third parties:

External third parties. This includes:
-Your AppStore Provider and mobile network operator to allow you to install the App.
-Service providers acting as processors based in the United Kingdom and India and provide IT and system administration services, hosting services for our App, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
-Our professional advisors acting as controllers based in the UK including lawyers, auditors, insurers, consultants.
-Your service providers that you have appointed and we need to contact to fulfil your requests such as your banking or payment card provider to process your transactions.
-Marketing and promotional partners and co-operatives acting as processors or controllers or joint controllers based inside OR outside of the UK with whom we share data to enhance our offerings and identify prospective customers.
-Third party partners where you have expressly subscribed to receive marketing from or with them.

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.

HM Revenue and Customs, regulators, law enforcement, public authorities or other third parties acting as controllers based in the UK where necessary to exercise our rights or comply with a legal obligation.

We may also from time to time sell your personal data to the following third parties:
External third parties. This includes:
Big Geo Inc based in Canada and the United States and Amazon Web Services Inc based in the United States for the purpose(s) of: date analytics and direct marketing purposes provided that we have obtained your prior consent before doing so. You will be able to withdraw your consent at any time (see YOUR LEGAL RIGHTS below for more information).

International transfers

Whenever we transfer (including where we sell) your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:

-We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us at support@studentsafetyapp.com.

We may also transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguard is in place:

-We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us at support@studentsafetyapp.com.

Please contact support@studentsafetyapp.com using the contact details above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers and located in the UK.

Any payment transactions carried out by us, or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer (“SSL”) technology.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App or Services, 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 protect your personal data from loss, unauthorised use or access.
We will collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology. Please see our Cookies Notice available at.

Certain Services may include social networking, chat room or forum features. Ensure when using these features that 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 detect and respond to personal data breaches and notify you and any applicable regulator when we are legally required to do so.

Data retention

By law we have to keep basic information about our customers (including Contact Data, Identity Data, Security Data and Transaction Data) for six (6) years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use, share and/or sell this information indefinitely without further notice to you.

If you do not use the App for a period of 2 (two) years then we will treat the account as expired and will delete your personal data.

Your legal rights

You have the following rights under data protection laws in relation to your personal data.

Right in relation to your personal data	Details
Access.	Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
Correction.	Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us).
Deletion.	Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we have processed your information unlawfully or where we need to erase your personal data to comply with law. In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.
Objection.	Object to us processing your personal data where: § we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or § the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
Restriction.	Request that we restrict or suspend our processing of your personal data: § if you want us to establish the data’s accuracy; § where our use of the data is unlawful, but you do not want us to erase it; § where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or § you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Data portability.	Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
Withdraw consent.	Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, 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.
Complain to the UK data protection regulator.	As mentioned above, 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 (www.ico.org.uk) or country-specific equivalent body. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

You can exercise any of these rights at any time by contacting us at: support@studentsafetyapp.com.

You can also use the Cookies Banner to give or withdraw your consent to or disable our processing of your Cookies Data, and the [Insert] sections of your Account or your local device settings to give or withdraw your consent to or disable our processing of your Location Data.