Effective April, 2020
By “Personal Data”, we refer to data that relates to you as an identified or identifiable natural person. The term “Personal Data” may include your name, your address, your telephone number, your e-mail address, your age, your gender, your game preferences for instance. Anonymous information, which we are not in a position to relate to you, does not qualify as “Personal Data”.
1. CONTROLLER’S NAME AND CONTACT DETAILS
Controller in the sense of the General Data Protection Regulation (GDPR) and other data protection or data privacy laws in the Member States of the European Union and other guidelines with a data protection nature regarding our (i) online and mobile applications including, but not limited to, SPEED TEST, SPORTS AR, associated web-sites such as www.awtg.co.uk, as well as any other AWTG Service, AWTG site or AWTG Software and any other websites owned or operated by AWTG is (hereinafter “AWTG Products”):
Address: 8 Canham Mews, Canham Road, London, W3 7SR, United Kingdom
In this Policy, “AWTG”, “we”, “us” or “our” means AWTG Limited. The term “Services” refers to the act of providing you with the opportunity to use the named AWTG Products, AWTG Software (“Software“) or related Account (“Account“), any of our other products and services (including support services, forums) related to the AWTG Products.
2. GENERAL INFORMATION IN BRIEF
We process personal data only when necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, or based on our legitimate interests, except where such interests are overridden by the interests or
fundamental rights and freedoms for which require the protection of your Personal Data.
Our legitimate interests are to render and improve our Services in an effective, safe and harmless manner. We want to provide everyone with a fair and balanced experience when using our Services.
3. INFORMATION SECURITY
We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.
4. PROCESSING INFORMATION BY THIRD PARTIES
We may share Personal Data with our affiliates, subsidiaries, vendors or agents working on our behalf for the purposes described in this Policy. For example, we may hire companies to assist with protecting and securing our systems or services. Any vendor or agent that we retain must comply with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Those companies may be located outside of the European Economic Area.
We recognize that we have a special obligation to protect personal information obtained from children. We will not knowingly collect Personal Data from any child, or process such information, without parental consent. For the purpose of this Policy, a child means any individual who is under the age of 18 (or the minimum legal age to consent to the collection and processing of Personal Data where this is different under applicable law).
6. DATA RETENTION
We keep most of your Personal Data gathered and processed for the purposes described in this Policy for as long as you continue to use our Services. We will delete your Personal Data after you request your Account deletion and the grace period of 45 (forty-five) calendar days, during which we can restore your Account, expires. The process of erasing your Personal Data can take up to one month from expiry of the grace period and, considering the complexity and number of requests, may be extended by a further two months.
7. THE KINDS OF INFORMATION WE COLLECT
Depending on which Services you use, we collect different kinds of information from or about you.
8. INFORMATION WE COLLECT DIRECTLY
We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information, e.g. while creating an Account.
When setting up an Account, you may be asked to provide Personal Data including, but not limited to, your name, email address and telephone number.
We may obtain your Personal Data when you register for and use our other Services, e.g. forums, chats, or when you provide feedback about our Services. This data includes:
- Information that you post, comment or like in any of the forums, on the pages of social network groups, in the applications and on the Site; share information such as pictures, videos, music and send messages or communicate using the AWTG Service and/or AWTG Software. This can include information in or about the content you provide, such as the time or location (when location-tagged) of a photo. We also collect information about how you use our Services, such as the types of content you view or the frequency and duration of your usage of the Service.
- Information you provide when you request information or support from us or purchase a product or service from us, including information necessary to process your orders with the relevant payment merchant, which may include the amount of any transaction, but will not include your financial information, which will only be submitted directly to the payment merchant under secure protocols;
- Information other than the Account Data you provide to us when participating in competitions, contests, games, tournaments, at offline events, responding to surveys, e.g. your contact details;
- Information that you provide to us to become a participant of any tests.
Things others do and information they provide:
We also collect content and information that other people provide when they use our Services, including information about you, such as when they share a photo of you, send a message to you, or import your contact information.
We collect information about the people and groups you are connected to using AWTG Services and/or AWTG Software and how you interact with them. We also collect contact information you provide if you upload such information (such as an address book) from a device.
Information from websites and apps that use our Services
We collect information when you visit or use third-party websites and apps that use our Services (like when they allow sharing to AWTG Service or AWTG Software). This includes information about the websites and apps you visit, your use of our Services on those websites and apps, as well as information the developer or publisher of the app or website provides to you or us.
Information from third-party partners
We receive information about you and your activities on and off AWTG from third-party partners, such as information from a partner when we jointly offer services.
Cookies and Log File Information
When you use the AWTG Service, our servers log certain general information that our application sends whenever a message is sent or received, or if you update or request any status information, including time and date stamps and the mobile phone numbers the messages were sent from and to.
9. INFORMATION WE COLLECT INDIRECTLY
We indirectly collect a variety of information through your interaction with and use of our AWTG products, ATWTG Software and other Services.
This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information (“Other Information”). Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular country. If Other Information is combined with Personal Data, we will treat the combined information as Personal Data.
We collect information from or about the devices where you install or access our Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices to helps us provide consistent Services across your various devices. Below are some examples of the device information we collect:
• Device information and identifiers such as the operating system, hardware version, device settings, application names, battery and signal strength.
• Device locations, including specific geographic locations, such as through GPS, or as provided through a network.
• Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
10. HOW WE USE YOUR INFORMATION
We need to process your Personal Data in order to perform the contract with you according to Article 6(1)(b) of the GDPR. As a user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes:
- to provide you with the Services you request, i.e., to ;allow your installation of the AWTG product, AWTG Software, operate the Services and verify and confirm your payments;
- to communicate with you about your Account or transactions with us and send you information about features on our Sites or changes to our policies;
- we conduct researches, test features in development, and analyze the information we have to evaluate, develop and improve products, services, or new features, and conduct audits and troubleshooting activities;
- to provide support including, but not limited to, product updates, product patches and fixes and other similar communications;
- to arrange receipt of gifts and awards, to which you may be entitled as a result of winning an offline competition, etc;
- we use the information we have to help verify accounts and activity, verify suspicious activities, check violation of our terms and services and to promote safety and security on and off of our Services. We work hard to protect your account using teams of engineers, automated systems, and advanced technology.
11. HOW WE SHARE YOUR INFORMATION
For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data:
- Sharing on Our Services
Users use our Services to connect and share with others such as sharing photos, videos, files and others.
- Users you share and communicate with
When you share and communicate using our Services, you choose the recipients who can see what you share. For example, when you post on AWTG, you select the recipients for the post, such as a customized group of individuals, all of your Friends, or members of a Group. Similarly, when you use chat, you also choose the people you send message or files to.
Some of this information you share can be Public Information such as any content you share with a public audience, to a public group, as well as information in your Public Profile, or another public forum. Public information is available to anyone on or off our Services and can be seen or accessed through various medias or search engines.
In some cases, people you share and communicate with may download or re-share this content with others on and off our Services. When you comment on another person’s post or like their content on AWTG, that person decides who can see your comment or like. If their audience is public, your comment will also become public.
- People that see content others share about you
Other people may use our Services to share content about you with the recipients they choose. For example, people may share a photo of you, mention or tag you at a location in a post, or share information about you that you shared with them.
- Apps, websites and third-party integrations on or using our Services
When you use third-party apps, websites or other services that use, or are integrated with, our Services, they may receive information about what you post or share. In addition, when you download or use such third-party services, they can access your Public Profile, which includes your username or user ID, your age range and country/language, your list of friends, as well as any information that you share with them. Information collected by these apps, websites or integrated services is subject to their own terms and policies.
- New owner
If the ownership or control of all or part of our Services or their assets changes, we may transfer your information to the new owner.
- Sharing with Third-Party Partners and Customers
We work with third party companies who help us provide and improve our Services or who use advertising or related products, which makes it possible to operate our companies and provide free services to people around the world.
We want our recommendations engine to be as relevant and interesting as the other information you find on our Services. With this in mind, we use all of the information we have about you to show you relevant activities around the area you defined. We do not share information that personally identifies you (personally identifiable information is information like name or email address that can by itself be used to contact you or identifies who you are) with advertising, measurement or analytics partners unless you give us permission. We may provide these partners with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you.
- Vendors, service providers and other partners.
When your personal data is shared with AWTG affiliates and subsidiaries, as well as third parties outside the European Union or the European Economic Area, AWTG guarantees an adequate level of personal data protection, including but not limited to, by entering into standard data protection clauses adopted by the European Commission with AWTG affiliates and subsidiaries, as well as such third parties.
12. YOUR RIGHTS
Information we retain. Upon expiry of the suspension period we will delete all Personal Data about you, except for the data that are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating. We will also retain anonymous information after your Account has been closed. Information you have shared with others will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other users copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
13. ADHERENCE TO THE LAW
We may collect and release Personal Data and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with national law, international law or respond to a court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual’s physical safety may be at risk or threatened. AWTG also reserves the right to disclose Personally Identifiable Information and/or non-personally-identifiable information that AWTG believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of AWTG Services or AWTG Software or our servers, and to protect the rights, property, or personal safety of AWTG, our users or others.
14. OUR COMMITMENT TO DATA SECURITY
AWTG uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to AWTG and you do so at your own risk. Using unsecured Wi-Fi or other unprotected networks to submit messages or share content through the AWTG Service or AWTG Software is never recommended. Once we receive your transmission of information, AWTG makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If AWTG learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. AWTG may post a notice on the AWTG Website or through the AWTG Service or AWTG Software if a security breach occurs.
15. SPECIAL NOTE TO INTERNATIONAL USERS
16. IN THE EVENT OF MERGER, SALE OR BANKRUPTCY
In the event that AWTG is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the (hopefully) unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.
17. WE CAN CHANGE THIS POLICY
We may change this Policy from time to time for various reasons, such as legal and regulatory changes, changes in industry practices and technological developments that need to be reflected.
For information about how to contact AWTG, please visit our contact page.