Last updated on 3 January 2022
K-Safe Ltd is a company incorporated in England (registration number 09836874) whose registered office is Sensor City, 31 Russell Street, L3 5LJ
(The “K-Safe Website(s)”) and the services we provide that are accessible via any of them (the “Services”).
INFORMATION WE MAY COLLECT FROM YOU
From time to time, we may collect or ask you to provide personal information including (without limitation) the following: your name, mobile phone number, email address, password, IP address, unique device identifiers and other identification credentials, biographical details, photographs and/or payment information.
As part of the Services, we may provide functionality allowing you to search for friends by using your Facebook credentials and, when you elect to do this, you will be asked to allow the Flare App to access certain information associated with your Facebook account such as your name, profile picture, gender and list of friends. Provided you consent to this, such information will be processed by us in order to identify your Facebook friends who are users of Flare App and to allow you to invite those Facebook friends to install the Flare App.
Please note that, with your consent, we will collect information about your location and physical movements in order for the Flare App to function properly and monitor and verify forms of eligible movement. You may turn location monitoring on and off from time to time using the settings of the operating system of your mobile device but, if you disable this functionality, we will not be able to collect information relating to your step-count and GPS/Cell-ID location which will prevent tracking and/or conversion of your movement into Flare Points.
We work with third parties from time to time (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide to us information about you. This may include your purchase history from business partners who supply you with rewards made available via the Flare App.
USES MADE OF YOUR PERSONAL DATA
We may use your personal data to:
provide the Services (using our own systems and those of appropriate third party service providers);
verify your physical movement and location and issue Flare Points on the basis of this verified data;
analyse the usage of, and improve, the Services;
perform market and customer research;
market our services to you;
correct errors and problems with the Services;
investigate and/or prevent suspected fraud or other criminal activities;
create daily leaderboards of users, comprising all users or users meeting particular criteria as ranked by the number of steps completed or using other criteria;
operate the Flare Marketplace; and/or investigate disputes between users.
Additionally, we and/or our trusted partners may contact you from time to time with offers that may interest you and/or inform you of other products and services. Certain of your personal data may be shared with other users of the Flare App as part of the normal operation of the Services (for example your uploaded profile picture and biographical information will be accessible to all users, and we may publish your total verified steps, or other movements, during a particular period to other users from time to time). Further, we may, from time to time, expand or reduce our business which may involve the transfer of certain divisions or assets of our company to other parties, and the data we store and use, where relevant, may be transferred to such third parties. From time to time we may transfer the data we store and use to locations outside the European Economic Area, some of which may have different data protection laws to the UK or the EU, or no data protection laws. In all such cases, we transmit such information only to entities that comply with this policy and applicable law.
Your personal data will be kept only for as long as is necessary. We take reasonable industry-standard care in keeping all our data secure and in preventing any unauthorised access or unlawful use of it. All personal data we store and the process is handled strictly in accordance with applicable data protection legislation.
The types of cookies we may use include:
Analytical/Tracking Cookies, which allow us to recognise and count the number of visitors and analyse the use of the Services, as well as to verify transactions; and
Advertising and Retargeting Cookies, which allow us to generate appropriate advertising directed to you on the K-Safe Website(s) as well as on the Flare App and other third party websites.
We use a number of industry-standard data analytics tools, such as Google Analytics and Facebook Analytics. These collect certain information about you, such as your device’s IP address and browsing and usage behaviour, and are used to allow us to track and monitor the traffic visiting the Flare App and K-Safe Website(s).
You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing (i.e. “opt-out”) by clicking ‘unsubscribe’ at the bottom of our marketing emails or by emailing email@example.com, with the subject ‘unsubscribe’.
You have the right to change your personal information we hold about you. You can exercise your right by accessing your Account information in our app (Open Flare app -> Settings Screen -> Account Management -> Change your details)
You have the right to ask us about the personal information we hold about you and to request a copy of your personal information. You can exercise your right to access this information by emailing firstname.lastname@example.org, with the subject ‘data access request’.
You have the right to delete your account and any personal information we hold on you. You can exercise your right to delete your Flare account and the personal information attached to it yourself, by triggering an account deletion via the Help section within the Flare app (Open Flare app -> Your Account Screen -> Settings -> Help -> Contact us -> Choose your problem = Delete Account) or, by emailing us at email@example.com.
Additionally, information about concerns or complaints may be made to the Information Commissioners Office in the UK via https://ico.org.uk/concerns.