GNM privacy policy for Serelay app (original) (raw)

Serelay Limited (Serelay) has developed the Serelay Idem Android/iOS mobile application (Serelay App or app) which enables verification and authentication of user generated content uploaded through the app. The app enables Guardian News & Media Ltd (GNM or us) to validate, verify the origin and authenticity of Guardian user generated content captured and submitted by Guardian users and readers, including, without limitation, photos and videos (UGC or content) to GNM.

If you wish to send content to GNM, you may download the Serelay App and use it to securely send your content to GNM. You can also still send your content to GNM by other means.

GNM is the controller of any personal information it receives from the Serelay App and will process your content and personal data in accordance with its terms and conditions (https://www.theguardian.com/help/terms-of-service) and privacy policy; (https://www.theguardian.com/help/privacy-policy) which you sign up to when you use the App and other GNM services.

This privacy policy is specific to the Serelay App and gives you details regarding our processing of your personal data when you use the Serela App and is supplemental to our main Privacy Policy. Before you proceed, please ensure you have read and understood this privacy policy together with the terms and conditions and the main Privacy Policy available via the following links : https://www.theguardian.com/help/terms-of-service; and https://www.theguardian.com/help/privacy-policy.

What we collect

When you use the Serelay App to send us your content, we will collect:

• your name and surname, email address, telephone number.

How we collect personal data

When you download the Serelay App and take a picture or video and give us permission, Serelay will transmit your personal details to us to enable us to verify the authenticity of the content you submit to GNM via the App.

How we will use your personal data

We use the personal data collected from you to contact you for more information that we may need to carry out our verification.

Legal grounds for using your personal data

• Consent: We receive your personal data from Serelay on the basis of the consent you have given for Serelay to transmit this information to us. You can withdraw your consent at any time. If you do, you will no longer be able to send information to us using the Serelay App, but you will still be able to use any other means that we have advised on our call outs. Any processing we have carried out based on your consent will still be valid.
• Our legitimate interests: legitimate interests means the interest of our business in conducting and managing our business. 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 have another lawful basis for doing so such as compliance with 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. When we receive your data, we will combine it with the verification data we have received and make an assessment of the authenticity of the information. We have a legitimate interest in ensuring that the information we publish is authentic and has not been tampered with.
• 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.

Compliance with law: this means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. In some cases, we may have a legal obligation to use or keep your personal data.We may reveal your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy,

Security of your personal data

We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. We employ strict contractual controls to ensure any organisation working with or for us apply the same measures.

Who we share your personal data with

We may share your personal data with one or more of our Guardian group companies currently based in the UK, US and Australia or with our service providers.

We will share the information that we have received from Serelay via the App to enable us to complete an authenticity assessment and to verify the content. We do this by matching that information other information on Serelay’s systems to receive a verification result.

We may disclose your personal data to our professional advisers and any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.

International data transfers

Data we collect may be transferred to, stored and processed in any country or territory where one or more of our Guardian group companies or service providers are based or have facilities.

Whenever we transfer your personal data out of the UK or the European Economic Area (EEA), we will only transfer to countries that have been found to have an adequate level of protection or use approved service contracts

If you are located in the UK or in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the UK or the EEA.

More information about our international transfers can be found in our full privacy notice.

Keeping your personal data

We keep your information for only as long as we need to for our purposes.

Your rights

• You have a right to see the information we hold about you. If you would like to have a copy of this or if you think that we hold incorrect personal data about you, please write to the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU or email dataprotection@theguardian.com.
• Where applicable, you may also have a right to receive a machine-readable copy of your personal data;
• You also have a right to restrict processing; object to processing; and to ask us to delete your personal data.
• If you have given consent for us to use your personal data, you can withdraw this at any time . We will always contact you to verify your details before publishing it. You can notify the Community team at this time or you can contact us using the following details – guardian.community@theguardian.com.

Contact us for information about how we use your personal data

If you want to exercise any of your rights or have any questions about how we use your personal data or you have a concern about how your personal data is used , please write to the Data Protection Officer at Guardian News & Media Limited, Kings Place, 90 York Way, London N1 9GU or email dataprotection@theguardian.com.

If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. If we decide to change our privacy policy we will post the changes here. If the changes are significant, we may also choose to email you with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.

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.

More information and details of our retention policy are set out in our privacy policy https://www.theguardian.com/help/privacy-policy.