Privacy Policy

Downtown London is a digital platform operated by Loqiva Limited, registered in England and Wales under company number 11212570, with its registered office at The Granary, Hermitage Court, Hermitage Lane, Maidstone, Kent, England, ME16 9NT ("the Provider", "we", "us", "our").

This Privacy Policy details how we collect, use and disclose personal information about you through your use of the Downtown London website and smartphone applications ("the App"), and by any other means.

We will only use your personal information as set out in this policy. Please read it carefully to make sure you understand how we treat your personal information. If you do not agree with the practices described here, please refrain from using the App.

We operate the App on behalf of Downtown London, whose content appears on it. We are the organization accountable for the personal information collected through the App under the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) ("PIPEDA"), unless we confirm otherwise to you in writing at the time your information is collected. Where we share information with [Downtown London], that organization is separately accountable for its own use of it.

We operate in accordance with PIPEDA and all other applicable Canadian privacy law and regulation relating to the security, use and disclosure of personal information.

1. COLLECTION OF DATA

We collect personal information about you which is obtained through:

The Information You Give Us

When you sign up and subscribe to our services or complete your profile, you provide us with personal information such as your name, email address and any other details you choose to add.
When you respond using our feedback tools, for example our survey and reporting modules, we collect the additional information you submit. You can choose whether or not to use these tools.

The Information We Collect About You

Location. Where you have granted permission on your device, we collect your location using GPS. This allows the App to present content that is relevant to where you are. Location information is treated as sensitive. You can turn location permission off at any time in your device settings, and the App will continue to work with reduced functionality.
Usage and device information. We collect information about your visit and use of the App, such as the duration of the visit, your IP address, operating system and the type of device used. This helps us with system administration, enables us to report on use of the App, and helps us to diagnose problems with our software and servers.
Tokens. We collect information through tokens stored on your device. Tokens are used to provide certain services on the App, to enable users and subscribers to access areas of the App, and to identify users correctly. Tokens keep your session live while the App is active and authenticate you as the correct user when the App is relaunched.We also collect information about you from third-party software providers integrated with our platform.
Third party integrations. We also collect information about you from third party software providers integrated with our platform.

We do not knowingly collect information about your health, financial account details, or any other category of sensitive information beyond location, and we ask that you do not submit it through the App.

2. WHY WE COLLECT YOUR INFORMATION

We collect, use and disclose your personal information for the following purposes:

To provide you with the App and its services, including updates relating to those services.
To present content, information, promotions and offers relevant to your location and interests.
To allow you to take part in interactive features of our services, where you choose to do so.
To administer, secure, maintain and improve the App and diagnose technical problems.
To produce aggregated and de-identified reporting for [Downtown London] about how the App is used.
To comply with our legal and regulatory obligations.

We will not use your personal information for a new purpose that a reasonable person would not consider appropriate in the circumstances without first obtaining your consent.

3. CONSENT

By signing up to use the App, you consent to our collection, use and disclosure of your personal information for the purposes described in this policy. Where the law requires express consent, including for collection of your precise location, we will ask for it separately, and you can grant or refuse it through your device.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent, contact our Privacy Officer using the details in section 11. Withdrawing consent may mean we can no longer provide you with some or all of the App's functionality.

4. MINORS

The App is not directed at children. If you are under the age of majority in your province or territory, please ensure that your parent or guardian has read this Privacy Policy and our Terms of Use, and has given consent for you to use the App. We will not knowingly collect personal information from a child under 13 without the consent of a parent or guardian. If you believe we hold information about a child collected without appropriate consent, contact our Privacy Officer and we will delete it.

5. SHARING YOUR INFORMATION

We will only disclose your personal information in accordance with this Privacy Policy, our Terms of Use, any other terms you agree to, or where we are required or permitted to do so by law.

Downtown London, for the purposes described in section 2.
Third party service providers who process information on our behalf, such as the Google Maps API, hosting providers and analytics providers. These providers are bound by contract to protect your information and to use it only for the purposes we specify.
Our professional advisers, who are bound by obligations of confidentiality.
Law enforcement, regulators, courts or other public authorities where we are legally required or permitted to disclose.
A prospective buyer or seller in the event that we sell or buy any business or assets, in which case your personal information may form part of the transferred assets.
Our affiliates, meaning our subsidiaries, our ultimate holding company and its subsidiaries.

We do not sell, rent or trade your personal information.

6. STORAGE AND PROCESSING OUTSIDE OF CANADA

We are a company based in the United Kingdom, and the App is hosted in the United Kingdom. Your personal information is transferred to, stored and processed in the United Kingdom by us and by our service providers.

While your information is in the United Kingdom, it is subject to the laws of the United Kingdom, and may be accessible to the courts, law enforcement and national security authorities of the United Kingdom under those laws. The United Kingdom has a comprehensive data protection regime under the UK General Data Protection Regulation and the Data Protection Act 2018, and we apply contractual and organizational measures designed to give your information a level of protection comparable to that required under Canadian law.

If you would like more information about our policies and practices regarding the processing of personal information outside Canada, please contact our Privacy Officer using the details in section 11.

7. SAFEGUARDS

We protect your personal information with security safeguards appropriate to its sensitivity, including access controls, encryption in transit and organizational procedures to prevent unauthorized access, use, disclosure, copying or modification.

Unfortunately, transmission of information over the internet is never completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of information you transmit to the App, and any transmission is at your own risk. Once we have received your information, we apply strict procedures and security features to try to prevent unauthorized access.

8. BREACH NOTIFICATION

If we determine that a breach of our security safeguards involving your personal information creates a real risk of significant harm to you, we will report the breach to the Privacy Commissioner of Canada and notify you as soon as feasible, and will notify any other organization that may be able to reduce the risk of harm. We keep records of every breach of security safeguards involving personal information under our control for a minimum of 24 months, as PIPEDA requires.

9. MARKETING & ELECTRONIC MESSAGES

We will not sell, rent or trade your personal information to third parties for marketing purposes.

We will only send you commercial electronic messages, such as marketing emails or push notifications, where you have given express or implied consent under Canada's Anti-Spam Legislation (S.C. 2010, c. 23). Every commercial electronic message we send will identify us, give our contact details, and include an unsubscribe mechanism that we will action within 10 business days. You can also withdraw marketing consent at any time by contacting our Privacy Officer or by adjusting your notification settings in the App.

We do not disclose information about identifiable individuals to advertisers. We may provide advertisers with aggregated, de-identified information about users, for example that a given number of users viewed an offer on a particular day, and we may use aggregated information to help advertisers reach the audience they want to target. We may then display an advertiser's content to that audience.

10. RETENTION, DELETION AND CORRECTION

We retain your personal information only for as long as necessary to fulfil the purposes set out in this policy, or as required by law. Where we have used your personal information to make a decision about you, we will retain it for at least one year after that decision so that you have a reasonable opportunity to request access to it.

You may unsubscribe from the App at any time by deleting your account. After a period of inactivity, we delete your account data from our servers automatically within 30 to 100 days.

If your contact details change and you cannot update them within the App, please email your new details to support@loqiva.com. If you believe any information we hold about you is inaccurate or incomplete, you may ask us to correct it, and where the correction is not made we will note your objection on the record.

11. YOUR RIGHTS

You have the right to ask us not to use your personal information for marketing purposes, and the right to access the personal information we hold about you and to be told how it has been used and to whom it has been disclosed.

To make an access or correction request, or to ask a question about this policy, contact our Privacy Officer:

Privacy Officer, Loqiva Limited
Email: support@loqiva.com

We will respond to an access request no later than 30 days after we receive it. We will provide the information at no cost, or at minimal cost. If any cost applies, we will tell you the approximate amount before we proceed, and you may then withdraw or modify your request. In limited circumstances set out in PIPEDA we may be unable to provide some information, in which case we will tell you why.

If you are not satisfied with our response, you may make a complaint to the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec, K1A 1H3
Toll free: 1-800-282-1376
www.priv.gc.ca

12. CHANGES TO THIS PRIVACY POLICY

If you have any questions or concerns about the information we hold about you, please email support@loqiva.com.