About this Notice
Nanny Louenna Limited (“we” or “us”) take the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our websites and app, or collected through other means such as by an online form, email, or telephone communication.
This notice applies to personal information provided by our contacts, users, registered users and subscribers whose data we process. In this notice “you” refers to any individual whose personal data we hold or process. This notice is governed by the EU General Data Protection Regulation and the UK General Data Protection Regulation (together, the “GDPR”).
This notice should be read in conjunction with the annexed CCPA/CalOPPA Appendix, which will apply to individuals residing in California from whom we collect personal information.
Personal data we collect and how we process this data
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:
Contact information for our contacts, users, registered users and subscribers such as names, email addresses, phone numbers, addresses (“Contact Information”). We process this information when we communicate with you or provide services to you on the basis of the performance of our contract with you and on the basis of our legitimate interest in providing our services to our users.
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 and on the basis of our legitimate interest in providing our services to our users.
Technical information we hold in relation to your use of our app or services, which parts of the app you access, the device you use and other relevant technical information. We process this information to ascertain how our users are using the app and to improve your use of the app and we process this data on the basis of of the performance of our contract with you and on the basis of our legitimate interest in providing our services to our users.
Marketing information we may hold about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and other information (“Marketing Information”). We process this information in order to communicate with you about our products and services on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receive the information.
We will collect information either from you directly or from a third party (for instance a mobile device app store). 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.
Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
Records relating to a contract with us - 7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim.
Marketing records - 3 years from the last date on which you have interacted with us.
For any category of personal data not specifically defined in this 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).
Sharing your information
We may disclose information to third parties in the following circumstances:
As part of our services we may provide information to our third party service providers;
We may disclose information to our group companies;
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;
We may transfer your personal information to a third party 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 any 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 information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
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.
Your privacy rights
With respect to your personal data, you have the right to:
Request that your personal data will not be processed;
Ask for a copy of any personal data that we have about you;
Request a correction of any errors in or update of the personal data that we have about you;
Request that your personal data will not be used to contact you for direct marketing purposes;
Request that your personal data will not be used for profiling purposes;
Request that your personal data will not be used to contact you at all;
Request that your personal data be transferred or exported to another organisation, or deleted from our records; or
At any time, withdraw any permission you have given us to process your personal data
All requests or notifications in respect of your above rights may be sent to us in writing at the contact details listed below. 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).
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager.
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 and UK
We will not transfer your personal data in a systematic way outside of the European Economic Area or the UK (together the “EEA + UK”) but there may be circumstances in which certain personal information is transferred outside of the EEA + UK, in particular:
If you use our services while you are outside the EEA + UK, your information may be transferred outside the EEA + UK in order to provide you with our services;
We may communicate with individuals or organisations outside of the services in providing our services, those communications may include personal information (such as contact information) for example you may be outside of the EEA + UK when we communicate with you;
From time to time your information may be stored in devices which are used by our staff outside of the EEA + UK (but staff will be subject to our cyber-security policies).
If we transfer your information outside of the EEA + UK, 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.
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 information or how it is handled, you can do so by us using the details below:
Address: 82 St. John Street, London, England, EC1M 4JN
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 www.ico.org.uk for further assistance.
23rd April 2021
The contents in this appendix apply to individuals residing in California from whom we collect personal information in compliance with the California Consumer Privacy Act (“CCPA”) and California Online Privacy Protection Act (“CalOPPA”) and are intended to supplement the information already contained in our privacy notice
Categories of Personal Information
Below we have set out the categories of Personal Information (as defined in the CCPA) collected in the previous 12 months and whether during such period, we have sold or otherwise disclosed such Personal Information for a business purpose (as defined in the CCPA).
Use, Collection and Disclosure of Personal Information
For details on how we use your personal information, please refer to the section “Personal data we collect and how we process this data”.
As set out above in our privacy notice, we generally collect information from you directly however we may also collect certain information from the organisation for whom you work (such as your contact information and job title/role) or other third party. If we obtain your personal data from a third party, your privacy rights under appendix are not affected and you are still able to exercise the rights contained within this appendix.
For details on who we share your personal information with, please refer to the section “Sharing your information” above.
Your California Privacy Rights
If you are a California resident, the CCPA provides you with certain specific rights in relation to your Personal Information, as set out below.
The Right to Receive Information on Privacy Practices and Access to Information (including as part of an Access Request) – i.e. the right to request certain personal information we have collected about you (including the categories and specific pieces of personal information).
The Right to Deletion – i.e. the right to request that we delete certain personal information which we have collected about you (subject to certain exceptions).
The Right to Receive Information about Onward Disclosures – i.e. the right to request information about personal information we hold about you which is either disclosed for a business purposes or sold.
The Right to Prohibit the Sale of your Information (also referred to as the Right to Opt Out) & the Right Not to be subject to Price Discrimination based upon the exercise of the Opt Out Right - however please note that we do not sell your personal information to third parties.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section 1798.83) permits users of our website/platform (as the case may be) that are California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes.
If at any time you would like to contact us with your views about our privacy practices, would like to exercise any of your rights as set out above or have another enquiry or complaint relating to your personal information, you can do so via email at firstname.lastname@example.org or by post to 82 St. John Street, London, England, EC1M 4JN.
We will accordingly aim to get to back to you as soon as reasonably practicable. To the extent you have made a specific request as set out under “Your California Privacy Rights”, we will confirm receipt of the request within 10 business days and respond more substantively to the request within 45 days from the time the request is received.