TOWNFISH LIMITED PRIVACY POLICY (NOVEMBER 2024)

Welcome to Townfish. Townfish is where locals can discover and connect with nearby places and people, read and publish local recommendations and find special offers and discounts in the form of mobile vouchers.

We invite you to read our privacy policy which is designed to show you exactly what data we collect from you and how we use and handle it. We believe you should have control over your data on TownFish and we want to help you make the best decisions about the information you share with us.

Townfish Limted (“we”, “us”, “our”) is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.

By using any of our professional services or giving us your personal information, you agree to your information being collected, stored, used and disclosed as set out in this privacy policy.

For the purposes of this policy Data Protection Legislation means: (up to but excluding 25 May 2018, the Data Protection Act 1998 and thereafter (i) unless and until the GDPR is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.),

Under the Data Protection Legislation, the data controller is Townfish Limited of 44 Park Avenue, Barking, Essex, IG11 8QU, a limited company registered in England and Wales. Registered number: 07481944. Registered Office: 44 Park Avenue, Barking, Essex, IG11 8QU

Unless indicated otherwise, this privacy policy (“Policy”) applies to all our website, domains, apps, products, services, and features (the “Services”).

You should also carefully read our Terms of Service which contain the full legal do’s and don’ts and terms about your membership and use of the TownFish services.

We use “TownFish” here to refer to the TownFish website and our iOS and Android apps (also referred to as our Services) that provide you with access to that platform. We also use “TownFish”, “we”, “us” and “our” to refer to the companies operating our Services.

TownFish is owned and operated in the United Kingdom by TownFish Limited and is registered in England at 44 Park Avenue, Barking, Essex, IG11 8QU. Email: info@townfish.com

If you have any questions about our policy, how we collect or process your data, how you can delete your data, or anything else related to our privacy practices, please contact us at any time. Email: info@townfiish.com

1. ABOUT US

TownFish is a hyperlocal social networking and voucher discovery platform for UK (and Wordwide) locations. Content posted to any of the website newsfeeds is immediately viewable and searchable by anyone around the world and via online search engines. There are some non-public ways to communicate on TownFish with other members including via Direct Messages.

When you register for membership on TownFish you must provide us with an email address, your date of birth, and your postal town in order to create an account. If you are registering as a business, agency or organisation you must also tell us your business type. You can choose to share additional information with us like your phone number, street address, and on your public profile you can choose to add information about your gender, work location, personal interests, occupation, current employer, country of origin, and university studied. This data is not mandatory or a condition for using TownFish or any of the services, you can choose to add or delete this data at any time. We use the information you provide for things like keeping your account secure and recommending you to relevant members, events, local deals, and other types of ads.

2. INFORMATION WE COLLECT WHEN YOU JOIN

You don’t have to create an account on TownFish to view public content posted in the location newsfeeds or to view public profile pages. If you chose to create an account, you must provide us with some personal data so that we can provide our services to you.

The personal data we may collect from you includes:

• Your full name (real name or pseudonym)
• a username
• Your date of birth (if you are representing yourself as a person)
• Your business type (if you are representing yourself as a business)
• Your business address (if you are representing yourself as a business)
• Your business telephone number (if you are representing yourself as a business)
• Your email address and communication preference
• Your postal town location (area in which you reside)
• Your country of origin
• The college or university where you studied
• Any feedback you may give us
• Your employer
• Your job title
• Your place of work (employers address)
• Data included in employment applications, including your employment history
• Information on how you use our website
• If relevant, how you use our web-based software products (SaaS)
• Your IP address, if you are using our web-based software products.
• Personal information related to your employment with Townfish Limited or any associated clients or third parties.

We use your postal town location to link you directly with associated newsfeeds on TownFish relevant to the same postal town location and also linking you with surrounding locations you might choose to interact in. You may also be assigned a different set of privileges to other members who are not associated with your postal town location.

Unless you choose to add it to your profile description, your email address will not be shown anywhere on TownFish publically. It can be seen by TownFish administrators in our Content Management System, in our databases and in third-party software services we use for the purpose of providing you with the Services.

3. HOW WE COLLECT YOUR DATA

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

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• request or receive our professional services;
• provide a service or product to us;
• apply for employment;
• communicate with us directly;
• request marketing to be sent to you; or
• give us some feedback.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• recruitment agencies;
• contractors;
• business partners;
• government agencies; and
• the Official Journal of the European Union.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Unfortunately, the transmission of information via the internet, email and telephone is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the internet, email or telephone. Once we have received your information we will use strict procedures and security features to try to prevent unauthorised access.

4. HOW LONG WE HOLD YOUR DATA

We will only retain your personal data for as long as it is needed for the purposes set out in the document, or for as long as we are required to by law. We will:

• Keep personal data obtained in a commercial capacity for as long as you are a customer of Townfish/customer contact of Townfish, or unsubscribe.
• Keep feedback while you are a customer of Townfish’s
• Keep employment applications, including CVs, for 2 years.
• Keep IP address from the usage of our web-based software products while you are a user of our SaaS, and ultimately for 2 years after you cease being a user.

5. HOW YOUR INFORMATION WILL BE USED BY US

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Where we have your consent, for example, if you have requested information from us or subscribed to our marketing/mailing lists.
• You have the right to withdraw consent to marketing at any time by contacting us.

6. PURPOSE FOR WHICH WE WILL USE YOUR PERONAL DATA

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We use the information you give us to tell you about other members, places, services, and products that we think you will find interesting. The more information you give us the more specific we can be. We do not pass your information onto any third parties, it is kept secure in our database servers which we use for the purpose of providing our services to you.

If you do not want a particular piece of information to be known about you it can be removed from your profile page or account settings. We all have reasons for keeping things secret and we respect that right.

We have set out in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the attached document.

View how and why we would use your data – November 2024

6.1 SOCIAL NETWORK INFORMATION

If you use Facebook to sign up for an account, or log in to TownFish (or later connect your Facebook  account to your TownFish account) you authorise Facebook to share your personal information with us, including your picture, name and email address.

6.2 LOCATION INFORMATION

In additional to asking you for your business or residential postal location when you register on TownFish, we also ask for permission to use the location services on your mobile device. We may collect and store data about your location such as your current precision position, or in geo locations in which your mobile device enters or exits. We do this so we can operate and personalise our services with more relevant recommendations to do with your current location such as local deals, events, featured items, and updates.

The difference when using a mobile device

There is no real difference except that as you move about, we monitor your location to make sure that we are giving you the best service.

With most mobile devices you can turn the location settings off – if you don’t want us to track you.

We also send updates in the form of push notifications to your phone when various changes and updates occur that are associated with your account, profile page, and the content you have published on TownFish.

6.3 INFORMATION WE COLLECT AND MONITOR WHEN YOU ARE LOGGED INTO YOUR ACCOUNT

We also collect the following information from your browser, computer, or mobile device. This provides us with technical information when you use TownFish:

• Device data which tells us about the device you’re using, what type and model it is, its operating system and version, its unique identifier, crash data (if applicable), and what settings you’ve enabled. Your device and software settings affect what information your device makes available to us.
• Log data which is automatically recorded by our servers based on data sent by your app or browser. This typically includes the date and time you visited, the browser or app version you used (and its settings), the URLs you come from and go to, your IP address and protocol, and how you used TownFish (for example, which links you clicked on).
• Cookie data which comes from “cookies” (small data files stored on your computer or mobile device) and similar technologies. Cookie data helps us recognize you, remember your preferences, and learn more about you. To learn more about the use of cookie data on TownFish see our Cookie Policy below in these Terms.

6.4 PUBLIC INFORMATION

Most activity on TownFish is viewable publicly, including your profile information, and the content you post in the forum newsfeeds. This includes certain information about your posts like the date and time of the post. Other information that is shown publicly are the list of TownFish member you choose to follow, recommendations and photos you have posted , the posts you have Liked, the events you have said you are ‘Going’ to (calendar marked), and also any comments, replies, and comments you have Appreciated or been given Appreciations by other TownFish members.

6.5 PAYMENT INFORMATION

You may be asked to provide us with payment information, including your credit or debit card number, card expiration date, CVV code, and billing address, in order to purchase goods and services provided via TownFish, in particular when making purchases using our mobile coupons and vouchers. We use this payment information to process transactions you have approved and also to detect fraud.

6.6 CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. WHO WE MAY SHARE YOUR INFORMATION WITH

We may have to share your personal data with the parties set out below for the purposes set out in the document titled How and Why we would use your data – November 2024.

• Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
• Service providers acting as processors based outside of the EEA including, but not limited to, our CRM provider (Hubspot) which is based in the United States of America.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Business partners, suppliers and sub-contractors for the purpose of performing our contract with you.

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. URL LINKS

In order to operate our services, we keep track of how you interact with url links across our services. This includes links in emails we send you and links in your post that might appear on other websites or mobile applications. If you click on an external link or ad on our services, that advertiser or website operator might figure out that you came from TownFish, along with other information associated with the ad you clicked such as characteristics of the audience it was intended to reach. They may also collect other personal data from you, such as cookie identifiers or your IP address.

9. COOKIE POLICY

Cookies are tools which allow us to identify you every time you visit our site. They also allow us to track you as you look at our site.

There are two types of cookies we use:

• Persistent Cookies – these are sent to your computer and stay with it until either you delete it or it’s time limit expires
• Session Cookies – these last only as long as you are on our site.

We use cookies to help make your experience browsing our site easier. A cookie contains no information about you but it may be linked with your personal information. We also use cookies to help us analyse our site; to help us administer the site; to prevent fraud and improve security on the site and to help target information and offers which we think may be of use to you.

Sometimes when you click a link on our site the people operating that link may use cookies as well. In that event you should examine their cookies.

9.1 AVOIDING COOKIES

You can avoid cookies in one of two ways:

1. If you leave our site you can then visit the “Tools” section of your browser to delete not just our cookies but any others.
2. In the “Tools” section of your browser, you will be given the option to “block cookies”

Please note that unless you enable cookies you WILL NOT be able to use this site nor get the best experience from other sites.

If you need any more information about cookies or our Privacy Policy, please contact us through the “Contacts” section or email info@townfish.com.

10. OUR CONTACT POLICY

If you get in touch with us we’ll always answer you. If you sign up for newsletters and similar services, again we’ll contact you.

The main part of our service is to give you information on local services, events, offers and deals which are relevant to the information you’ve given us. If you don’t want to hear from us anymore you can simply deactivate your account.

11. IF YOU ARE UNDER 16

Membership is not available to anyone under 16 and if you try to join and we find out, we will stop your membership immediately. We ask that you are honest with us so that we can help you.

If you do try and join and we cancel your membership, we may well keep a note of your IP and email addresses to stop you registering again until you are able.

12. HOW YOU CONTROL THE INFORMATION YOU SHARE WITH US

On TownFish you decide and control:

• What information is added and displayed on your personal profile
• Who can send you a Direct Message
• What content you want to view, from which users, and in which locations
• When to publish or delete your content

12.1 OPTING OUT

You can ask us or any third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

12.2 YOUR RIGHTS TO YOUR PERSONAL DATA

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the section at the end of his privacy notice for further details.

If you wish to exercise any of these rights, please contact the Data Privacy Representative at Townfish Limited, 44 Park Avenue, Barking, Essex, IG118QU OR info@townfish.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

‍What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

‍Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

‍Your legal rights to request

You have the right to:-

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

13. HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us at info@townfish.com

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

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Contact information

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Data Privacy Manager, Townfish Limited, 44 Park Avenue, Barking, Essex, IG118QU OR info@townfish.com

CONTACT FORM PRIVACY POLICY

We inform you that your personal data will be processed by Townfish Limited. for the management of suggestions, questions, requests for information, or any type of communication sent by its clients or by third parties, in relation to Townfish. Your consent legitimises this data processing. Likewise, we inform you that your data will be kept for 2 years from the receipt of the online form. You can exercise your rights of access, rectification, cancellation, opposition, limitation of treatment and, in the event that the treatment is carried out by automated means and, as long as it is technically possible, the right of portability of your data in accordance with the provisions of applicable legislation in personal data protection, by contacting Townfish Limited, 44 Park Avenue, Barking, Essex, IG118QU OR info@townfish.com, duly proving your identity. Likewise, we inform you that the contact details of the Data Protection Officer of Townfish are those mentioned above. You have the right to file a claim with the corresponding Supervisory Authority, if you consider your rights infringed. You can withdraw your consent anytime.