Last Updated on June 8th, 2020. This Privacy Policy is effective immediately for Users after that date.

23 Ltd (“we,” “us,”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This policy describes:

  • the types of information that we may collect from you when you access or use our Mobile App – and other online services (collectively, our “Services”); and
  • our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies only to information we collect through our Services and in the electronic communications sent through or in connection with our Services.

DEFINITIONS

User

“User” or “you” or “your” refers to you, as a user of the Services. A user is someone who accesses or uses the Services for the purpose of sharing, displaying, hosting, publishing, transacting, uploading information or viewing pictures and includes other persons jointly participating in using the Services.

User Account

“User Account” is a separate part of the Mobile App, containing User information required during registration.

Content

“Content” will include (but is not limited to) images, photos, audio, video, location data, ‘nearby places’, and all other forms of information or data.

23 Ltd qualifies as a Data Controller under the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 (General Data Protection Regulation (the “GDPR”)). As such, we aim to comply with all legal obligations which the GDPR implies on Data Controllers.

23 Ltd strives to offer its visitors and Users the many advantages of Internet technology and to provide an interactive and personalized experience. For these purposes, we, from 23 Ltd, may use personally identifiable information – like your name, e-mail address, address, telephone number, etc., which are subject to the terms of this Privacy Policy. We, and we suppose you too, do not tolerate spam. We will therefore never sell, barter, or rent your email address to any unauthorized third parties.

We

We refers to the BCTs app.

1. WHAT INFORMATION DO WE COLLECT FROM OUR USERS?

We collect only data which is essential to our operations and enables us to provide you with better user experience.

The information, through which the person may be identified, may include data, which the User voluntarily enters, uses or provides when using the Services of the BCTs Mobile App, or submits when creating a User Account. 23 Ltd collects and uses the information for the purposes, outlined in this Privacy Policy, as well as to offer new services to the User or to familiarize him with new functionalities on the Mobile App.

We may also use certain performance tracking tools, such as Google Analytics. Through the use of Google Analytics we gather information regarding your behaviour and preferences when using our online platform.

We collect two types of information from and about our Users, including information:

  • by which you may be personally identified; and/or
  • about your internet connection, the equipment you use to access our Services and your usage details (i.e. your Internet Service Provider).

The information we collect on or through our Services may include:

User Account information: Personal information, such as your full name and other information you may provide with your account, such as your address and phone number, that may be displayed as a part of your User Account;

— We collect this information in order to verify your identity and provide you with an individualised experience of our Services.

Contact Information: Your contact information, such as email address and other ways of communication.

— We collect this information in order to provide you with access to certain features of our Services and to inform you about relevant information concerning your use of our Services.

Preferences: Your preferences and settings such as time zone and language;

— We collect this information in order to enhance your user experience.

Searches and other activities: The search terms you have looked up and results you selected;

— We collect this information in order to improve your user experience and provide you with more relevant content and Services.

Browsing information: How long you used our Services, which features you used, etc.;

— We collect this information in order to analyse the behaviour of our users and improve our Services.

Communications: Between you and 23 Ltd support staff regarding the Services.

— We collect this information in order to monitor the quality of our support staff and your communications with us.

Transactional information: If you make payments or purchases through our Services, we may collect and store information about you to process your requests and automatically complete forms for future transactions;

— We collect this information in order to enhance your buying experience.

Information from third parties: We may collect, process and store your user ID associated with any social media account (such as your Facebook and Google account) that you use to sign into the Services or connect with or use with the Services. This could include, without limitation, any information that you have made public through a given social media account of yours.

— We collect this information in order to provide you with an easier and faster access to our Services.

Location Data: We may collect information about your location if you have instructed your mobile device or computer to send such information via the privacy settings on that mobile device or computer. We may use the location data collected to enhance your use of the Services by providing you with relevant content and contextual advertising.

2. HOW WE GATHER INFORMATION FROM USERS

How we collect and store information depends on the pages you are visiting, the activities in which you elect to participate and the services provided. For example, you may be asked to provide information when you register for access to certain portions of our Mobile App, create a User account, request certain features, such as e-mail newsletters or when you make a payment. Like most Mobile Apps, 23 Ltd also collects information automatically and through the use of electronic tools that may be transparent to our visitors and Users. For example, we may log the name of your Internet Service Provider.

3. THE LEGAL BASIS WE RELY ON

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including legitimate interest.  We use a legitimate interest basis to collect and process your data in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interest. Specifically, we process your data as described in section 4.

If you wish to opt out of this collection and processing of your personal information, you may do so at any time. To do so, please complete the form within the app:

iOS: Help > About this app > Opt out of the experiment

Android: Settings > Opt out

As all your data is anonymised this is the only way we can locate your data.

4. WHAT WE DO WITH THE INFORMATION WE COLLECT

Like other Mobile Apps, we collect information to enhance your visit and deliver more individualised content. We respect your privacy and do not share your information with anyone, except in cases when that proves necessary.

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. Specifically, we will retain the information we collect from you for a maximum period of 2 years. After the expiry of this period we undertake to delete any information we have collected from you.

Aggregate information and information that does not personally identify you, may be used in many ways. For example, 23 Ltd may combine information about your usage patterns on the Mobile App with similar information obtained from other users to help enhance our site and Services (e.g., to learn which pages are visited the most or what features Users find the most attractive). This information does not include any information about you and does not allow anyone to identify you individually. We may use personally identifiable information, collected on the Mobile App, to communicate with you about your registration and customisation preferences; our Terms of Service and Privacy Policy; services and products offered by or through the Mobile App; and other topics we think you might find of interest. Personally identifiable information collected by 23 Ltd may also be used for other purposes, including but not limited to Mobile App administration, troubleshooting, processing of e-commerce transactions, creating an ever more effective product, contribution to publications that add to the scientific literature, and and other communications with you. Certain third parties who provide technical support for the operation of our Mobile App – our Web hosting service for example – may have access to such information. We will use your information only as permitted by law. We may also disclose your information in response to a court order, at other times when we believe we are reasonably required to do so by the applicable law, in connection with the collection of amounts you may owe to us, and/or to law enforcement authorities, whenever we deem it appropriate or necessary. Please note we may not provide you with notice prior to disclosure in such cases.

We may use personal information we collect from you, such as age, gender, interests, activities etc. in order to better understand your behaviour and provide you with the most relevant content and advertisements. We use this information to serve you with more relevant advertisements, a process also know as Remarketing.

For example, you may see certain advertisements on the app, this website or other websites due to the fact that we contract with Google and other similar third parties, to target our advertisements based on the information we or they have collected, including but not limited through automated means, such as cookies.

You may opt out of the automated collection of information by changing your preferences at http://www.google.com/settings/ads.

5. CHANGE OR REVIEW OF INFORMATION

If you would like to review, change or delete personal data we have collected from you or you had submitted or permanently delete your account, please complete the form within the app:

iOS: Help > About this app > Opt out of the experiment

Android: Settings > Opt out

For more information regarding the termination or deletion of your information, please refer to Section 10: Termination of this Privacy Policy.

6. ACCESSING & CORRECTING YOUR PERSONAL INFORMATION.

We take reasonable steps to accurately record the personal information that you provide to us, as well as any subsequent updates.

We encourage you to review, update, and correct the personal information that we maintain about you. You may request that we delete personal data about you that is inaccurate, incomplete, irrelevant for legitimate purposes, or is being processed in a way which infringes any applicable legal requirements. To do so, please complete the form within the app:

iOS: Help > About this app > Opt out of the experiment

Android: Settings > Opt out

7. SECURITY: HOW WE PROTECT YOUR INFORMATION

23 Ltd is registered as a Personal Data Controller pursuant to European Union law.
We have implemented appropriate measures in the form of various technical, physical and other means, including, but not limited to measures regarding the security of out electronic systems and databases, locks, racks, cases and other devices and access controlling systems, fire-notifying and fire extinguishing systems. These means aim at improving the integrity and security of the personal information that we collect and maintain. However, please be advised that even the best security measures cannot guarantee the full elimination of all risks. If we learn of any violation, breach or danger to our security systems breach, then we will attempt to notify you electronically so that timely and appropriate protective steps can be taken. Apart from informing you via e-mail, we may post a notice through the Mobile App if a security breach occurs.

Your personal data safety is of utmost importance to us. We review and strive to improve our security measures on a regular basis.

If we detect a breach of our security measures, which has the potential of harming you as individual we will notify you without undue delay.

8. CONTROLLING YOUR PERSONAL DATA

Other Users may be able to identify you, or associate you with your account, if you include your personal information in any content you post or make publicly available.

You may control and restrict the personal data you share with us by contacting us at support@null23.co.uk

If you have any questions regarding the ways you can control your personal data, please contact us at support@null23.co.uk.

9. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We sometimes share your personal data with trusted third parties. For example, our scientific partners at University College London, IT companies who support us with data management and storage, IT companies who work with us to make improvements to the app.

When we share your data with those organisations to keep your data safe and protect your privacy we ensure that:

  • We provide only the information they need to perform their specific services,
  • They may only use your data for the exact purposes we specify in our contract with them
  • We work closely with them to ensure that your privacy is respected and protected at all times
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the European Economic Area.

10. TERMINATION

As mentioned, you may at any time review or change the personal information we maintain about you by completing the form within the app. Upon your request, we will delete your personal data from our active databases.
This Privacy Policy is effective until terminated by either party. If you no longer agree to be bound by this Privacy Policy, you must cease the use of the 23 Ltd App. If you are dissatisfied with 23 Ltd, its content, or any of these terms, conditions, and policies, your sole legal remedy is to discontinue using the Mobile App. 23 Ltd reserves the right to terminate or suspend your access to and use of the Mobile App, or parts of them, without notice, if we believe, in our sole discretion that such use is in violation of any applicable law, or harmful to our interests or the interests of another person or entity, or where 23 Ltd has reasons to believe that their use is in violation of this Privacy Policy or the Terms of Use.

11. CHILDREN’S PRIVACY

23 Ltd does not knowingly collect personal information from children under the age of 13. If we learn that we have personal information on a child under the age of 13, we will delete that information from our servers. 23 Ltd encourages parents to go online with their kids.

12. CHANGES TO THIS POLICY

23 Ltd reserves the rights to change this Privacy Policy at any time. Please check this page periodically for changes. Your use of the services after any such amendment or change in the Privacy Policy shall be deemed as your express acceptance to such amended/changed Privacy Policy and an assent to be bound by such changed/amended Privacy Policy. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

13. GOVERNING LAW.

This Privacy Policy and the use of the Mobile App are governed by the laws of United Kingdom. The parties undertake to first try to resolve the dispute with by negotiation. If the parties fail to reach an amicable resolution through negotiation, 23 Ltd agrees to submit the dispute to the competent Court of United Kingdom.

14. COPYRIGHTS.

The copyrights of our Mobile App are the property of 23 Ltd.

Texts, graphics, photographs, animations, videos and clips, visible on the Mobile App are the object of copyright and are part of the intellectual property of 23 Ltd. Those @may not be reproduced, used, presented or represented without an explicit written permission by 23 Ltd. Any distribution of files, obtained by the Users under the Terms and Conditions of the Mobile App, or of parts of such files, constitutes a violation of the relevant intellectual property protection laws and is prosecuted by the law.

Nothing contained on this Mobile App may be interpreted as granting a license or right of use as a trademark without the prior explicit written consent of 23 Ltd.

15. CONTACT

If you believe 23 Ltd does not adhere to this Privacy Policy, to address a question, to resolve a complaint regarding the Mobile App or the 23 Ltd Services, or to receive further information regarding the Services, please contact our data protection officer via email at support@null23.co.uk.

If you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns; please note we can’t be responsible for the content of external websites)

16. MISCELLANEOUS

23 Ltd is controlled, operated and administered entirely within United Kingdom.

If you are accessing the BCTs Mobile App from another jurisdiction, please be advised that you are transferring your personal information to 23 Ltd in United Kingdom and, by using the Mobile App, you consent to that transfer and to abide by the applicable laws concerning your use of the Mobile App and your agreements with us.

This statement and the policies outlined in this Privacy Policy are not intended to and do not create any contractual or other legal rights in or on behalf of any third party.
23 Ltd may provide a translation of the English version of the Privacy Policy into other languages. You understand and agree that any translation of the Privacy Policy into other languages is only for your convenience and that the English version shall govern your rights and responsibilities. In case there are any inconsistencies between the English version of the Privacy Policy and its translated versions, the English version of the Terms shall prevail.