Last updated: March 07, 2019

Introduction

Macro 4 Limited is committed to protecting your personal data and respecting your privacy.

This policy applies to your use of the Company's mobile applications:

  • Columbus mobile applications software ("Columbus App"); and
  • Any of the services accessible through the Columbus 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 Columbus 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

Macro 4 Limited is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or our" in this policy). Macro 4 Limited’s registered office is The Orangery, Turners Hill Road, Worth, Crawley, West Sussex, RH10 4SS, United Kingdom, telephone number +44 (0) 1293 872000.

We have appointed a Privacy and Risk Management Committee ("PRMC"). If you have any questions about this privacy policy, please contact them at compliance@macro4.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office ("ICO"), the United Kingdom ("UK") supervisory authority for data protection issues, or other competent supervisory authority of a European Union ("EU") member state, if the Columbus App is downloaded outside the UK.

Changes to the Columbus mobile applications privacy policy and your duty to inform us of changes.

We keep the Columbus mobile applications privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of your personal data, that we collect, changes during our relationship with you.

The data we collect about you

The Columbus App is downloaded from external application stores ("App Site"). The information you provide to the App Site is not available to us. The Columbus App is designed to access a copy of Macro 4’s Columbus software, fully licensed by an end customer. The end customer (being "Your Organization") may hold your personal information depending on how it is configured, however, this information also is not available to us. Your Organisation must, by law, have a privacy notice explaining how they are using your personal data.

The different kinds of personal data we may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data: None - while using the Columbus App, you may be asked to provide certain personally identifiable information that can be used to contact or identify you. Any Identity Data collected by the App Site or Your Organisation is not available to us.
Contact Data: None - billing address, delivery address, email address and telephone numbers are not available to us. Any Contact Data collected by the App Site or Your Organisation is not available to us.
Financial Data: None - your bank account and payment card details provided to the App Site or Your Organisation are not available to us.
Transaction Data: None - details about payments to and from you, provided to the App Site or Your Organisation, is not available to us.
Device Data: When you access the Columbus App by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use and other statistics ("Log Data").
Content Data: None – some information stored on your Device may be available to the App Site or Your Organisation, but it is not available to us.
Profile Data: None - your username and password provided to the App Site or Your Organisation is not available to us.
Usage Data: Details of your use of our Columbus App may be provided to us via the App Site, however, such information is only available in aggregated form and therefore will not contain any personally identifiable information.
Marketing and Communications Data: None.
Location Data: None.

The App Site may collect data such as statistical or demographic data for any purpose, which is later presented us in an aggregated form. 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, your Usage Data may be aggregated to calculate the percentage of users accessing the Columbus App within a specific date range.

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
    You do not provide us with any personally identifiable information. Any personal data required to download and use the Columbus App is collected by the App Site provider and Your Organisation respectively.

  • Information we collect about you and your device
    We do not collect any personally identifiable information. The App Site provider and Your Organisation may collect information about you and your device when using the Columbus App.

  • Location Data
    No data is collected by us.

  • Information we receive from other sources including third parties and publicly available sources
    No data is collected by us.

  • Unique application numbers
    No data is collected by us.

Cookies

Cookies are small text files that may be placed on your computer or other mobile or handheld device (e.g. smartphone or tablet) via your internet browser when you visit a website. They are tracking technologies to distinguish you from other users of an app, app site or the distribution platform and to remember your preferences.

The Columbus App does not use cookies to collect information.

How we use your personal data

We do not use your personal data. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data.

Purposes for which we will use your personal data

We do not use your personal data. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data.

Disclosures of your personal data

We do not use your personal data so there are no disclosures made. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data.

International transfers

We do not use your personal data so there are no international transfers made. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software, and related international transfers, should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data, including international transfers.

Data security

We do not use your personal data so there are no data security requirements. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software, and related data security, should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data, including data security.

Data retention

We do not use your personal data so there are no data security requirements. Any personal data used by Your Organisation in providing you access via the Columbus App to the Columbus software, and related data retention, should be covered by Your Organisation’s privacy notice. Similarly, any App Site you use to download the Columbus App should have a privacy notice explaining how they are using your personal data, including data retention.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data – see section "Glossary Your legal rights" for more information.

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 compliance@macro4.com

Glossary

Lawful basis

Consent 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.
Legitimate Interest 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.
Performance of Contract 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.
Comply with a legal obligation Processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Your legal rights

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 d. 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.