Privacy Policy
Introduction
This policy (together with our end user licence terms, together our Terms of Use) applies to your use of:
- the Reefill App mobile application software (App), once you have installed or streamed a copy of the App onto your mobile telephone or handheld device (Device).
- Any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
WLI (UK) Ltd is the controller and is responsible for your personal data ("we", "us" or "our" in this policy).
We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
Contact details
Our full details are:
- Full name of legal entity: WLI (UK) Ltd
- Title of data privacy manager: Legal Director
- Email address: legal@waterlogic.com
- Postal address: 1 Grenfell Road, Maidenhead, Berkshire, SL6 1HN, UK
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 24/03/2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Third party links
Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data: first name, last name, username or similar identifier
- Contact Data: email address.
- Device Data: includes a unique identifier specific to your device and your mobile operating system.
- Profile Data: includes your username and password, feedback and survey responses.
- Usage Data: includes details of your use of any of our Apps.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
- Location Data: includes your precise or approximate current location determined by your IP address or your mobile device’s GPS.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms within the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you install the App, record your use of one of our water dispensing machines in the App, share data via the App's social media functions and when you report a problem with the App or our Services. If you contact us, we will keep a record of that correspondence.
- Location Data. We also use GPS technology and/or your IP address to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location data in your device’s settings.
- Information we receive from other sources including third parties. We receive Device Data from the relevant app store which you used to install the App.
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered 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.
Purposes for which we will use your personal data
Purpose/activity | Type of data | Lawful basis for processing |
To install the App and register you as a new App user | Identity Contact Device | Your consent |
To deliver Services to you | Identity Contact Device Marketing and Communications Location | Your consent Performance of a contract with you Necessary for our legitimate interests (to provide the App features to you) |
To manage our relationship with you including notifying you of changes to the App or any Services | Identity Contact Profile Marketing and Communications | Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
To enable you to participate in a prize draw, competition, complete a survey or provide feedback on the App | Identity Contact Device Profile Marketing and Communications | Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
To administer and protect our business and this App including troubleshooting, data analysis and system testing | Identity Contact Device | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App | Identity Contact Device Content Profile Usage Marketing and Communications Location | Consent Necessary for our legitimate interests (to develop our products/Services and grow our business) |
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:
- Other companies in the Waterlogic Group and who provide IT and system administration services and undertake leadership reporting.
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- 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 policy.
International transfers
Our external third parties may be based outside the UK so their processing of your personal data will involve a transfer of data 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:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data retention
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
You can at any time request that we delete your personal data stored in relation to your use of the App by using the “delete account” function within the App. [We may however retain certain personal data of yours, where we have a lawful basis for doing so.]
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
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:
- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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
- 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.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at reefillsupport@waterlogc.com