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Privacy Policy for Eloqntly

Introduction

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Eloqntly ("we," "us," or "our") is committed to protecting and respecting your privacy. This Privacy Policy outlines how we collect, use, store, and disclose your personal information when you use our mobile application ("App") and services. By downloading, accessing, or using Eloqntly, you agree to the terms of this Privacy Policy.

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1. Data Controller

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For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, the data controller is:

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Eloqntly Ltd​

483 Green Lanes, London, England, N13 4BS

john@eloqntly.co.uk

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2. Information We Collect

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A. Personal Data

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We may collect and process the following personal data about you:

  • Identity Data: First name, last name, date of birth.

  • Contact Data: Email address, telephone number.

  • Profile Data: Username, password, profile picture, personal bio.

  • Usage Data: Information about how you use our App, including challenges completed, levels achieved, events attended, and interaction with resources.

  • Technical Data: IP address, login data, browser type and version, time zone setting, device type, operating system and platform.

  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.

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B. Special Category Data

Given the nature of our App, some users may voluntarily share information related to their speaking anxiety or mental health. We treat such data with the highest level of confidentiality and security.

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3. How We Collect Your Personal Data

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

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  • Direct Interactions: You provide personal data when you fill in forms, create an account, participate in challenges, attend events, or communicate with us.

  • Automated Technologies or Interactions: As you interact with our App, we may automatically collect Technical Data about your equipment and browsing actions.

  • Third Parties or Publicly Available Sources: We may receive personal data about you from analytics providers, advertising networks, and search information providers.

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4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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  • Performance of Contract: To register you as a user and provide the services you have requested.

  • Legitimate Interests: To improve our App, manage our relationship with you, and administer our business.

  • Consent: Where you have given consent for specific purposes, such as receiving marketing communications.

  • Compliance with Legal Obligations: To comply with applicable laws and regulatory requirements.

 

Purposes for Using Your Personal Data:

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  • To Provide and Maintain Our Services

    • Personalise your experience based on your progress and preferences.

    • Track your challenges, levels, and achievements.

    • Facilitate event registrations and participation.

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  • To Manage Your Account

    • Process your registration and maintain your account.

    • Authenticate your identity and provide account security.

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  • To Communicate with You

    • Send you service-related communications, including confirmations, technical notices, updates, and support.

    • Respond to your inquiries and provide customer support.

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  • To Improve Our Services

    • Analyze usage and performance to improve the App's functionality.

    • Develop new features and services based on user feedback.

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  • For Marketing and Promotional Activities

    • Send you newsletters, promotions, and information about events and services that may interest you.

    • You can opt out of marketing communications at any time.

  • To Ensure Security and Prevent Fraud

    • Monitor for suspicious or fraudulent activity.

    • Enforce our terms and policies.

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5. Disclosure of Your Personal Data

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We may share your personal data with:

  • Service Providers: Third-party vendors who provide services such as hosting, data analysis, payment processing, customer service, and email delivery.

  • Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

  • Event Partners: Third parties involved in organizing or hosting events you attend through the App.

  • Regulatory Authorities: If required by law or to protect our rights, property, or safety, or that of our users or others.

  • Business Transfers: In connection with any merger, sale, or transfer of company assets, we may share your data with the relevant third parties.

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

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6. International Transfers

Your personal data may be transferred to and processed in countries outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Transferring to countries that have been deemed to provide an adequate level of protection for personal data.

  • Using specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. Measures include:

  • Encryption: We use encryption protocols to protect data in transit and at rest.

  • Access Controls: Access to your personal data is limited to those employees, agents, contractors, and other third parties who have a business need to know.

  • Security Assessments: Regular testing and evaluation of our security measures.

Despite these precautions, no data transmission over the internet or method of electronic storage is completely secure.

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8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.

  • Retention Periods: Details of specific retention periods for different aspects of your personal data are available upon request.

  • Criteria for Determining Retention Periods: The nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and legal requirements.

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9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Access: Request access to your personal data.

  • Rectification: Request correction of inaccurate or incomplete data.

  • Erasure: Request deletion of your personal data where there is no good reason for us to continue processing it.

  • Restriction: Request restriction of processing your personal data.

  • Data Portability: Request the transfer of your personal data to you or a third party.

  • Objection: Object to processing of your personal data where we are relying on legitimate interests.

  • Withdraw Consent: Withdraw consent at any time where we are relying on consent to process your personal data.

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To exercise any of these rights, please contact us at john@eloqntly.co.uk.

 

No Fee Usually Required

You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive.

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Time Limit to Respond

We aim to respond to all legitimate requests within one month.

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10. Cookies and Similar Technologies

Our App uses cookies and similar technologies to distinguish you from other users. This helps us provide a better experience and allows us to improve our App.

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  • What Are Cookies? Small data files stored on your device when you visit a website or use an app.

  • How We Use Cookies: To understand usage patterns, improve functionality, and provide personalized features.

  • Managing Cookies: You can set your device to refuse all or some cookies. However, if you disable or refuse cookies, some parts of the App may become inaccessible or not function properly.

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11. Third-Party Links

Our App may contain links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy statements.

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12. Children's Privacy

Eloqntly is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will delete that information promptly. If you believe we might have any information from or about a child under 13, please contact us.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated Effective Date. We encourage you to review this Privacy Policy periodically.

  • Significant Changes: If we make material changes, we may notify you by email or through a notice on the App.

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14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

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15. Complaints

If you are unhappy with how we have used your personal data, you have the right to make a complaint to the Information Commissioner's Office (ICO):

  • Information Commissioner's Office

    • Website: https://ico.org.uk/

    • Telephone: 0303 123 1113

    • Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

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We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

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16. Lawful Basis Glossary

  • Legitimate Interest: Processing is necessary for our legitimate interests (or those of a third party) provided that your interests and fundamental rights do not override those interests.

  • Performance of Contract: Processing your data where it is necessary for the performance of a contract to which you are a party.

  • Compliance with Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject.

  • Consent: You have given clear consent for us to process your personal data for a specific purpose.

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