Most people don’t read privacy policies, but you’re here - so congratulations! Check you out! Our lawyer will be so excited.
At Bits we want to make ‘small print’ easy to understand. Sometimes, however, you can’t translate legal wording accurately. We’re sure you’re totally up to speed with the real-life meanings contained within EU Directive 96/46/EC and it’s secondary legislation - but until politicians and lawyers start talking in plain english, we’re obliged to give you some confusing ‘small print’. That ‘small print’ is at the bottom of this page for the thirsty legal eagles amongst us. For everyone else, here’s the ‘not-so-small-print’.
What data we can access
What data we need to use and how we’ll use it
What we’re responsible for and what you’re responsible for
What kind of data is this about?
It’s about the data you allow us to use day-to-day:
When you visit our website or use our app
When you give us some of your data for a specific reason
What data do you need to use and why?
Your date of birth
Your email address
Your mobile number
We use your name and date of birth to prevent fraud and to make sure you are who you say you are.
We use your email address to contact you about your account.
We use your mobile number to provide a more secure login process called ‘two factor authentication’, also known as 2FA.
We can, of course, only use this data if you allow us to use it. We get this data when:
You actually give it it to us - doing things such as filling in a form, creating an account or contacting us about something
By using our products - doing things like using our website or app, which produces website statistics - statistics like ‘where your computer is linking from in the world’ and ‘how many times did you press that button before it finally worked’ (don’t worry, we’ll fix that button).
How will you use that data?
If you fill in a form, create an account or contact us, we only use that data to create and maintain your account or contact you about your account. Nothing more. No spamming. No selling. No creepy Ads. If you visit our website or use our app, we only use those statistics to work out how the app or website is being used - and to make it better for you to use in the future. Here’s how we’ll communicate it:
Forms, accounts and contacting us? We’ll ask your permission to use your data.
Visiting the website or app? We’ll presume you’re ok with us capturing those anonymous statistics - otherwise we’d have to bother you asking permission every time you visited us. You know, like those other annoying websites with the pop-ups.
If you’re not happy with any of this, you can tell us you’re not happy and we’ll delete any data you want us to delete.
Who will you share my data with?
This is the important one, so best pay attention. We’re very tight on this. That Facebook stuff freaked us out too, and it’s why we don’t have a Facebook sign-in option in the app. At Bits we only allow your data to be accessed by:
Our staff, customer support people and close advisors (like lawyers) - we do this so we can keep building Bits and give you good customer service.
Our payment providers - this are the people who transact money on our behalf, and they need to know you are who you say you are. We need to do this to keep your payments safe and prevent fraud.
Some software tools we use - this is things like our mail service provider (we use Mailchimp). We only use software tools that have solid data and privacy policies, and we choose those tools carefully.
And that’s all. A pretty small select bunch of responsible people. These people sign a contract saying your data is kept secure, meaning they can’t tell anyone about it or sell it, and in the case of the software tools we use, we make sure they are certified as handling data safely and maintaining privacy with their customers.
How do you keep my data secure?
This is a two way thing, so let’s not get hacked by working together!
We’ll make sure your account has a unique username and password to protect it - or a legit authorisation login. You’ll make sure that password is secure, hard to crack and you won’t tell everyone what it is.
We’ll soon offer two factor authentication (2FA) to increase security around login. You’ll use it when it’s available.
We’ll store any data we have on super secure encrypted servers. You’ll make sure to tell us if you think you’ve been hacked or there’s some funny looking things happening. You can tell us here if you think you’ve been hacked by pressing this button:
How long will you hold my data for?
We only use your data to maintain your account or to improve your experience, so unless we’re using it for that, we’ll delete it. We don’t want to hold any of your data longer than we need to - because keeping data secure ain’t cheap. We only hold data longer if we need it for legal, tax or governmental reasons, and only then if it’s securely archived.
What are my legal rights?
This is very important, so definitely read this bit. You have a lot of legal rights to your data, because your data belongs to you, not us. You have:
The right to ask what data we have about you
The right to correct that data if it is incorrect (and we hope you would)
The right to delete any data we have about you
The right to tell us how that data can be used
The right to move, copy or transfer that data
The right to object to your data being used
If you want to flex those rights for whatever reason, you can here:
What happens if Bits gets sold or changes ownership?
When a business changes hands a lot of crazy things happen. But nothing crazy happens with your data. If Bits does change hands, you’ll not only be notified of it happening, but:
We will maintain your privacy and rights over your data
The new owner or prospective owner has to agree to maintain your privacy and rights over your data
So nothing changes. You’re still in control. It’s all cool.
I’m a legal eagle - where’s the actual small print with that ‘Directive 96/46/EC’ thing in?
Welcome scholar. Please see below for the full legalese version.
Definitions and interpretation
Collectively all information that you submit to Fea Card Limited via the Website. This definition incorporates, where applicable, the definitions
provided in the Data Protection Laws;
Data Protection Laws
Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or
the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
the General Data Protection Regulation (EU) 2016/679;
Fea Card Limited, or us
Fea Card Limited, a company incorporated in England and Wales with registered number 11620703 whose registered office is at 110b
Camden Street, London, NW10HY;
User or you
Any third party that accesses the Website and is not either (i) employed by Fea Card Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Fea Card Limited and accessing the Website in connection with the provision of such services; and
The website www.getbits.app, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
the Fea Card Limited app (“App”) once you have downloaded a copy of the App onto your mobile telephone or handheld device.
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses,
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
4. For purposes of the applicable Data Protection Laws, Fea Card Limited is the "data controller". This means that Fea Card Limited determines the purposes for which, and the manner in which, your Data is processed.
5. We may collect the following Data, which includes personal Data, from you:
b. date of birth;
c. contact Information such as email addresses and telephone numbers;
How we collect Data
6. We collect Data in the following ways:
a. data is given to us by you; and
b. data is collected automatically.
Data that is given to us by you
7. Fea Card Limited will collect your Data in a number of ways, for example:
a. when you contact us through the Website, the App, by telephone, post, e-mail or through any other means;
b. when you register with us and set up an account to receive our products/services;
Data that is collected automatically
8. To the extent that you access the Website, we will collect your Data automatically, for example:
a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of Data
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
a. internal record keeping;
b. improvement of our products / services;
10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
11. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
13. We may share your Data with the following groups of people for the following reasons:
a. our employees, agents and/or professional advisors - to allow them to run the service;
Keeping Data secure
14. We will use technical and organisational measures to safeguard your Data, for example:
a. access to your account is controlled by a password and a user name that is unique to you.
b. we store your Data on secure servers.
15. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: firstname.lastname@example.org.
17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
18. You have the following rights in relation to your Data:
a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: email@example.com.
20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
24. We may also disclose Data to a prospective purchaser of our business or any part of it.
25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
28. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
29. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
29 March 2019