2.1.2 The Services are not intended for use by individuals aged below the minimum age at which bars, pubs and nightclubs licensed to sell alcohol on-premises ("Venues") may serve you alcohol (without the presence of another person, such as a responsible adult) pursuant to your local laws (the "Minimum Age"). For example, the Minimum Age in the United Kingdom is 18. We do not knowingly collect or process any information from persons under the Minimum Age, including children, at any time.
2.2.1 Muddle Technologies Limited is the controller and is responsible for your personal data.
2.3.2 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us using the details set out above in the first instance.
2.4.3 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 your relationship with us.
2.5.1 The Services may include links to third party websites, plug-ins and applications ("Third Party Services"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymised data).
3.2 The Services consist of a highly personalised, gamified map-based pub, bar and nightclub discovery app with powerful filtering features and unique real-time offers. To ensure the Services operate effectively, and to make sure you get the most out of the Services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
3.4 We do not collect any special categories of personal data about you (this includes details 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), with the exception of information about whether you recognise yourself as disabled where you select the "only show venues with disabled access and facilities" option via your profile page within our mobile applications.
3.5 We do not collect any information about criminal convictions and offences.
4.1 We use different methods to collect data from and about you including through:
5.1.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.1.2 With respect to lawful bases that we will rely on to process your personal data (as further set out in Section 5.2):
5.1.3 Generally, we only rely on consent as a legal basis for processing your personal data in connection with our direct marketing communications to you (including via email). You have the right to withdraw consent to marketing at any time via your profile page in our mobile applications (whether iOS, Android or otherwise) or using the "unsubscribe" button in the footer of our marketing communications.
5.2.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate). Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose / activity||Type of data||Lawful basis for processing|
|To register you as a new user of the Services||
||Performance of a contract with you|
|To provide you with the Services that you request from us||
To manage our relationship
with you, including:
|To enable you to partake in a prize draw, competition or complete a survey||
To administer and protect
our business and the
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
Necessary for our legitimate
interests – to:
To use data analytics to
Necessary for our legitimate
interests - to:
|To provide advertising to you and make suggestions and recommendations to you about goods or services that may be of interest to you||
Necessary for our legitimate
interests - to:
5.2.2 In any or all of these circumstances, we may perform these functions directly or use carefully selected third parties to perform these functions on our behalf. Where we use a third party, that third party will be subject to written agreements with us that restrict the third party’s use of your personal information strictly to those activities necessary to perform their services to us.
5.2.3 Please note that we do not sell your personal data without your consent (whether your name, address, emails address, or otherwise) to any third party, including Venues or advertisers, unless it is first anonymised.
5.3.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your personal data use, which can be located in your profile page via our mobile applications (whether iOS, Android or otherwise).
5.4.1 We may use your identity data, contact data, technical data, location data, usage data and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this "marketing").
5.4.2 You will receive marketing communications from us if you have:
5.5.1 Advertising service providers, companies and networks may display advertisements via the Services from time to time. We do not provide any non-anonymised personal information to these third parties, but they may use tracking technologies (such as cookies or web beacons) to collect information about you if you view or interact with their advertisements.
5.5.2 Some of these third parties may be members of the Network Advertising Initiative, which provides you with a single location to opt out of advert targeting from member companies. See Section 5.6.1(d) below for further details on opting-out of data collection.
5.6.1 We are committed to giving you the ability to take control of your personal information. You can use the following mechanisms to delete or prevent us from receiving your information (including deleting existing cookies or disabling future cookies), though note that doing so may prevent you from accessing certain features or functionality of the Services:
5.6.2 Please note that opting out of cookies, mobile device IDs, or advertising IDs does not mean you will stop seeing advertising in the Services. However, the company or companies from whom you opted-out will no longer deliver adverts tailored to your web preferences and usage patterns, which means you may see a greater number of adverts that are not relevant to you or your preferences.
5.6.3 ‘Do Not Track’ (“DNT”) is a privacy setting that users can set in their web browsers to inform websites that you do not want those websites to collect certain information about you. While we have provided you with the opt-out links and details above so you can take control of your personal information, please note that we do not currently recognise or respond to any DNT signals as the Internet industry continues to work towards defining a common approach to, and meaning of, DNT compliance.
5.7.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
5.7.2 If we need to use your personal data for an unrelated purpose, we will notify you (which may be via the Services, email or otherwise) and we will explain the legal basis which allows us to do so.
5.7.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6.1 We may share your personal data with the carefully selected third parties set out below for the purposes set out in the table at Section 5.1 above:
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7.1 We share your personal data within the Muddle Group and with External Third Parties that may be based outside of the European Economic Area (EEA). This will involve transferring your data outside the EEA.
7.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
8.1 When using the Services via our desktop or mobile websites, we use the following categories of ‘cookies’ (small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page) to collect information and store your preferences:
8.3 You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Services.
9.1 It is very important to us that we keep you, and your personal information, secure. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
9.2 We take a number of steps, and use a number of technical and organisational measures, to try to protect the personal information that you provide. These include:
9.3 We will notify you and any applicable regulator of a breach where we are legally required to do so.
10.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
10.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10.3 In some circumstances you can ask us to delete your data: see Section 11 below for further information.
10.4 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 this information indefinitely without further notice to you.
11.1 Your rights
11.2 No fee usually required
11.3 What we may need from you
11.4 Time limit to respond
12.1 You may close your account at any time via the profile page in our mobile applications (whether iOS, Android or otherwise).