PRIVACY POLICY

Last modified 18-Nov-21 UK time.

This Privacy Policy (“Privacy Policy”) should be read in conjunction with the Terms of Service available at https://heckle.app/tos.

Pickup Infinity Limited, a company registered in England and Wales is registered with the ICO and has paid the required data protection fee.

This Privacy Policy serves as the Privacy Notice required under the UK GDPR and EU GDPR. We are also compliant with the CCPA and endeavour to disclose and follow best practices in data protection using a principle of highest common denominator.

  1. SUMMARY

    We do not sell your personal information.

    We only use your personal information to:

    • provide the Service;
    • protect the integrity of the Service;
    • validate authorized users of the Service;
    • to provide analytics to help Us and Our advertisers understand the users of the Service and to provided targeted advertising where consent has been given. (We fully respect the user choice allowed in iOS 14.5+ to request not to be tracked, in which case non-targeted advertisements may be shown.)

    Many of the above validation, analytics and advertising services are provided by Google Inc under the relevant privacy policies.

  2. PERSONAL INFORMATION COLLECTED

    We collect and process your personal information as follows:

    1. Personal identifiers (name and email address, other login methods)
      • Purpose: To create and maintain your account, and to authenticate you to the Service.
      • Justification: Contractual necessity
    2. Username and profile details (profile picture and bio, followers, people you invite):
      • Purpose: To allow you to share this information with other users of the Service. You should consider this information public and be careful about what you share, especially if it is personal or sensitive.
      • Justification: Contractual necessity
    3. Audio/video and comments
      • Purpose: Sharing live and recorded audio/video and comments are the core feature of the Service. You should consider this information public and be careful about what you share, especially if it is personal or sensitive.
      • Justification: Contractual necessity
    4. Device and connection details (including IP address, device type, OS version), and interactions with Service
      • Purpose: To allow Us to debug, protect, improve the Service, and to detect and respond to use outside the Terms of Service
      • Justification: Legitimate interest
    5. Interactions and communications with Us
      • Purpose: If you interact with Us via email, Twitter DM or other communications channel, We will retain the contact information and message content in order to be able to respond and follow up.
      • Justification: Legitimate interest

  3. PERSONAL INFORMATION STORAGE

    Account information is securely stored in Google cloud services based in the USA.

    Audio/video and comment data is securely stored and processed in various cloud services based currently in the USA and EU.

  4. PERSONAL INFORMATION RETENTION

    Personal information is retained for as long as you continue to hold an account with the Service.

    You may choose to remove any audio/video broadcast you have contributed on the Service from visibility to other users. We may retain such broadcast information securely and privately for a period of up to one month in order to be able to respond to reports of inappropriate behaviour, or for any longer period as required by law enforcement activities.

  5. PERSONAL INFORMATION SHARING

    Limited (non-tracking) personal information is shared with Google for the purpose of delivering advertising and for analytics. This is currently done without any tracking identifiers.

  6. DATA PROTECTION RIGHTS AND COMPLAINTS

    Under data protection law, you have rights including:

    • Your right of access - You have the right to ask Us for copies of your personal information.
    • Your right to rectification - You have the right to ask Us to rectify personal information you think is inaccurate. You also have the right to ask Us to complete information you think is incomplete.
    • Your right to erasure - You have the right to ask Us to erase your personal information in certain circumstances.
    • Your right to restriction of processing - You have the right to ask Us to restrict the processing of your personal information in certain circumstances.
    • Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
    • Your right to data portability - You have the right to ask that We transfer the personal information you gave Us to another organisation, or to you, in certain circumstances.
    • You are not required to pay any charge for exercising your rights. If you make a request, We have one month to respond to you.
    • Please contact Us via @HeckleHelp on Twitter or via post to Pickup Infinity Limited, 1-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom if you wish to make a request.

    How to complain: If you have any concerns about Our use of your personal information, you can make a complaint to Us at Pickup Infinity Limited, 1-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.

    You can also complain to the ICO if you are unhappy with how We have used your data. The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom. Helpline number (UK): 0303 123 1113. ICO website: https://www.ico.org.uk