Maslife Ltd is a limited company registered in England and Wales, with the company number 11534603 and registered office at 21 Knightsbridge, Belgravia, London, England, SW1X 7LY.
MasLife Ltd respects your privacy and is committed to protecting your personal data.
- MASLIFE v.1 mobile application software (App) available in the App Store on Google Play Store, once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).
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.
1. IMPORTANT INFORMATION AND WHO WE ARE
MasLife Ltd is the controller of the App and is responsible for your personal data (collectively referred to as “MasLife”, “we”, “us” or “our” in this policy).
Full name of legal entity: MasLife Ltd
Email address: email@example.com
Postal address: 21 Knightsbridge, Belgravia, London, England, W8 4SG
Telephone number: 08001694216
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
This version was last updated on 24th June 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. 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.
Our Sites may, from time to time, contain links to and from the websites of our partner networks, third party service providers, 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. Please check these policies before you submit any personal data to these websites or use these services.
2. THE DATA WE COLLECT ABOUT YOU
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data includes first name, maiden name, last name,username or similar identifier, marital status, title, date of birth,gender, proof of address and identity documents.
- Contact Data includes address, email address and telephonenumbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from youand other details of products and services you have purchasedfrom us.
- Device Data includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
- Content Data includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins, steps, floors and distance data.
- Profile Data includes your username and password, purchases ororders made by you, your interests, preferences, feedback andsurvey responses.
- Usage Data includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
- Location Data includes your current location disclosed by GPS technology.
3.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, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
- • Location Data. We also use GPS technology 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 settings or contacting us.
- • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public source] as set out below:
- Device Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks ; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators or from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- • 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.
4.HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to do so. We will rely on the following types of lawful basis to process your personal data:
- Where you have consented before the processing. Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
- Where we need to perform a contract we are about to enter or have entered with you. Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- 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. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes
Purposes for which we will use your personal data
||Type of data
||Lawful basis for processing
||Specific Third Parties we will share your Personal Data with
|To install the App and register you as a new App user
|(a) Your consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to verify your ID for money laundering or other anti-crime purposes)
|(a) Onfido Ltd (processor)
(b) Prepaid Financial Services Ltd
(joint data controller)
(c) Twilio Inc (processor)
|To provide our services to you including:(a) Verifying your Identity Data
(b) Deliver yourprepaid Card andset up yourAccount/ E-Wallet
(c) Manage your Account/E-Wallet including payments, fees, charges and currency exchange
(d) Collect and recover money owed to us
(e) Deliverwebinars to you
(f) Sign you up tothe Maslife community
(f) Marketing and Communications
|(a) Your consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to verify your ID for money laundering or other anti-crime purposesand recover debts due to us)
|a) The Currency Cloud Ltd (processor)
(b) Onfido Ltd (processor)
(c) Prepaid FinancialServices Ltd(joint data controller)
|To manage our relationship with you which will include:
(b) Notifying you about charges youare responsible for
(c) Asking you to leave a review or take a survey
(e)Marketing and Communications
|(a) Your consent
(b) Performance of a contract with you
(c) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
(d) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|(a) The Currency Cloud Ltd(processor)
(b) Prepaid Financial Services Ltd(joint data controller)
(c) Intercom Software UK Limited(processor)
|To enable you to partake in a prize draw, competition or complete a survey
(e) Marketingand Communications
|(a) Your consent
(b) Performance of a contract with you
(c) 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 website (including anti-money laundering requirements, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, toprevent fraud and inthe context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|(a) Onfido Ltd(processor)
|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
(g) Marketing and Communications
(b) Necessary for our legitimate interests (to develop our products/Services and grow our business)
5.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 Purposes for which we will use your personal data:
External Third Parties:
- Service providers based in the EEA who provide IT and systemadministration services.
- Professional advisers including lawyers, bankers, auditors andinsurers based in the EEA who provide consultancy, banking, legal,insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based inthe United Kingdom who require reporting of processing activitiesin certain circumstances.
Specific Third Parties. These third parties are listed in the table Purposes forwhich we will use your personal data above and their Privacy Policies can befound in the links below:
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.
We do not transfer your personal data outside the European Economic Area(EEA).
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights 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.
In the event that you do not use the App for a period of 3 years then we will treat the account as expired and your personal data may be deleted.
9.YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws inrelation to your personal data. You have the right to:
- Request access to your personal data (commonly known asa “data subject access request”). This enables you to receive acopy of the personal data we hold about you and to check that weare lawfully processing it.
- Request correction of the personal data that we hold aboutyou. This enables you to have any incomplete or inaccurate datawe hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us.·Request erasure of your personal data. This enables you toask us to delete or remove personal data where there is no goodreason for us continuing to process it. You also have the right to9 ask us to delete or remove your personal data where you havesuccessfully exercised your right to object to processing (seebelow), where we may have processed your information unlawfullyor where we are required to erase your personal data to complywith local law. Note, however, that we may not always be able tocomply with your request of erasure for specific legal reasonswhich will be notified to you, if applicable, at the time of yourrequest.
- Object to processing of your personal data where we arerelying on a legitimate interest (or those of a third party)and there is something about your particular situationwhich makes you want to object to processing on thisground as you feel it impacts on your fundamental rightsand freedoms. You also have the right to object where we areprocessing your personal data for direct marketing purposes. Insome cases, we may demonstrate that we have compellinglegitimate grounds to process your information which override yourrights and freedoms.
- Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of yourpersonal 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 usto erase it.
- Where you need us to hold the data even if we no longerrequire it as you need it to establish, exercise or defend legalclaims.
- You have objected to our use of your data but we need toverify whether we have overriding legitimate grounds to useit.
- Request the transfer of your personal data to you or to athird party. We will provide to you, or a third party you havechosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies toautomated information which you initially provided consent for usto use or where we used the information to perform a contract withyou.
- Withdraw consent at any time where we are relying onconsent to process your personal data. However, this will notaffect the lawfulness of any processing carried out before youwithdraw your consent. If you withdraw your consent, we may notbe able to provide certain products or services to you. We willadvise 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 firstname.lastname@example.org.