MOREPAWS PRIVACY POLICIES

Last updated August 2023.

This privacy relates to your use of our mobile application software and all data we supply with the software and any updates or supplements to it (the “app”) and our website at morepaws.co.uk (the “website”) (together, “MorePaws”). It also applies to any other interaction we may have with you, such as where you contact us, you sign up to our mailing list, you sign up as an affiliate, or anything else.
For further information about MorePaws, you should read our terms and conditions available at https://morepaws.co.uk/terms-and-conditions. This policy and the terms and conditions will govern your use of MorePaws at all times.
Your privacy is important to us. This policy sets out information on the personal data we collect about you, and your rights in respect of that data.
MorePaws is owned and operated by MorePaws Limited, a company registered in England and Wales under company number 14303146 with its registered office at 12 Lynway Drive, Manchester, United Kingdom, M20 4TS (“we” or “us”).

By downloading, signing up to or using MorePaws, whether as a user or as a business owner, you accept these terms and agree to comply with them. If you don't accept them, you must not use MorePaws

1. About us

We will only process your personal data in line with data protection laws, namely the EU law retained version of the General Data Protection Regulation ((EU) (2016/679), the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directives) Regulations 2023 (the “Data Protection Regulations”). If any of these laws are replaced or superseded, we will also comply with those.
We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB518694. If you have any concerns about data protection, we would appreciate it if you contacted us first so we can discuss these with you before you approach the ICO. You can reach us at hello@morepaws.co.uk

2. The data we may collect about you

Personal data/information means any information about an individual from which that person can be identified. It doesn't include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, family name, last name, username or similar identifier, marital status, title, date of birth and gender
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details
Technical Data includes internet protocol (IP) address, your login data, 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 MorePaws.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use MorePaws, our products, and our services.
Location Data includes information about your physical location (explained later in this policy).
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences

Aggregated Data such as statistical or demographic data for any purpose, isn't considered personal data in law as this data will not directly or indirectly reveal your identity to us. We may aggregate your Usage Data to calculate the percentage of users accessing a specific app or website feature.

We don't 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). We also don't collect any information about criminal convictions and offences.

3. How is your personal data collected?

We may use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact by filling in forms, by corresponding or engaging with us by post, phone, email, social media or otherwise.
Automated technologies or interactions. As you interact with MorePaws, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Google, Companies House, or the electoral register.

4. How we use your personal data

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

Where we need to perform the contract, we are about to enter into or have entered into with you
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
Where we need to comply with a legal obligation.

5. Purposes for which we will use your personal data

We have set out below the ways we may use your personal data, and which of the legitimate bases we rely on to do so:

Purpose/Activity	Type of data	Lawful basis for processing including basis of egitimate interest
To enable you to submit an enquiry to us, whether via email, phone, through our MorePaws or via social media, ncluding but not limited to LinkedIn, Twitter, Facebook and nstagram	Identity Contact	a) Performance of a contract with you b) Necessary for our legitimate interests (to enable us to respond to your enquiry)
To enable you to sign up as a user of MorePaws or as an affiliate, or business advertising on MorePaws	Identity Contact	a) Performance of a contract with you
To process and deliver your subscription to MorePaws ncluding: a) Manage payments, fees, and charges b) Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	a) Performance of a contract with you b) Necessary for our legitimate interests (to recover debts due to us)
To enable you to share your ocation on MorePaws	Location Data	a) Performance of a contract with you b) Necessary for our legitimate interests (to enable you to make use of this feature of MorePaws)
To enable you to sign up as an affiliate	Identity Contact	a) Performance of a contract with you
To manage our relationship with you which will include: a) Notifying you about changes to our terms or privacy policy b) Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	a) Performance of a contract with you b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests (to keepour records updated and to study how customersuse our products/services)
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	a) Performance of a contract with you b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To enable you to register for our mailing list/email marketing	Identity Contact Marketing and Communications	a) Performance of a contract with you b) Necessary for our legitimate interests (to enable us to provide you with the newsletter/email marketing and present you with information, goods or services we consider you will be interested in)
To administer and protect our business and MorePaws including troubleshooting, data analysis, testing, system maintenance, support,	IdentityTechnical	a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand he effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve MorePaws, our products/services, marketing, customer relationships and experiences	Technical Usage	a) Necessary for our legitimate interests (to define ypes of customers for our products and services, to keep MorePaws updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Marketing and Communications	a) Necessary for our legitimate interests (to develop our products/services and grow our business)

6. Location data

Location data is defined as information collected by a network or service about where the user's phone or other device is or was located – for example, tracing the location of a mobile phone from data collected by base stations on a mobile phone network. Within this policy, where we refer to your personal data or personal information, this includes the location data outlined in this section.

We are permitted to collect your location data as we are a provider of a value-added service, we have your consent to the use of your location data for the value-added service, and our processing of your location data is necessary for that purpose. By downloading the app and using MorePaws, you are consenting to our collection and processing of your location data.

The type of location data we collect and process is your exact physical location and coordinates, or where you exact physical location and coordinates of the place that you tagged yourself on MorePaws.

We will use the location data you choose to provide to us so that you can share your location with other users, thereby enabling you to make use of the services MorePaws provides.

The lawful basis for collection of this information is it is needed to perform our contract with you (i.e., to enable you to use the services offered by MorePaws ), it is in our legitimate interest (i.e collect and sharing your location data is a feature of MorePaws), and you have consented (i.e., by choosing to provide us with your location data).

7. Marketing

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you haven't opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this won't apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

8. Cookies

Our website uses cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and Data Protection Regulations to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies, and may include:

Google Analytics> – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information.
Facebook Ads (the Facebook pixel)> - these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website's functionality.
Google Ad Words> – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website's functionality
Google Maps> – these cookies collect anonymous information about how visitors use a website that integrates Google Maps, used to improve the website's functionality and make marketing communications more relevant and to enable certain features, such as providing directions, search results, and other location-based information.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you, including some elements of video advertising. If at any time you wish to disable our cookies, you can do so through the settings on your browser, or whenever the pop-up appears on the website (each time you access the website).

9. Disclosures of your personal data

We may disclose your information in the following cases:

If we want to sell our business, or our company, we can disclose it to the potential buyer
We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
We can exchange information with others to protect against fraud or credit risks.

We may also contract with third parties to supply services to you on our behalf. These include:

Credit card processing services
Order fulfilment service providers
Analytics service providers
Event/campaign management service providers
Website management service providers
Information technology and related infrastructure provision
Email delivery services
Our auditors and legal advisors

It is important to note that these third party processors are bound by data protection obligations in the same way that we, or any company that processes personal data is.

10. Data security

Data security is of great importance to us, and to protect your personal data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further reoccurrence. It is important to note that we can only do our best to protect your personal data but the transmission of information over the internet is not entirely secure. Any personal data you share with us over the internet is done at your own risk.

11. International transfers

We may transfer your personal data outside of the UK or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

12. Data retention

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.
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

13. Your legal rights

Under certain circumstances, you have rights under the Data Protection Regulations in relation to your personal data:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us by emailing hello@morepaws.co.uk.

You won't have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances.

We try to respond to all legitimate requests within one month, but it could take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. Third party links

This policy only relates to MorePaws and to our business activities. We might have links on/within MorePaws to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

15. Changes to this policy

We can update this policy from time to time as laws change or as MorePaws or our services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.