Privacy Policy

 

    • Laduma Creative Enterprises Limited (we/us/our) is committed to protecting the privacy and security of your personal information.
    • This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).
    • Laduma Creative Enterprises Limited of Liverpool, Suite 1, Sixth Floor, Walker House, Exchange Flags, Liverpool, L2 3YL, UK is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
    • This notice applies to current and former clients / customers. This notice does not form part of any contract we may have with you, but may in certain instances be incorporated into our agreements, by reference or otherwise. We may update this notice at any time.
    • It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
  • DATA PROTECTION PRINCIPLES
    • We will comply with data protection law. This requires that the personal information we hold about you must be:
  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept for only as long as it is necessary, for the purposes we have told you about.
  • Kept securely.
  • INFORMATION WE MAY COLLECT FROM YOU
    • Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    • We maycollect, store, and use the following categories of personal information about you:
  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Financial data such as Bank account or credit card details.
  • Video footage and other information obtained through electronic means such as swipe-card records, but not limited thereto.
  • Information about your use of our information and communications systems.
  • Photographs, video or other digital and/or media content.
  • Location information.
  • Technical information as more particularly set out below.
  • HOW IS YOUR PERSONAL INFORMATION COLLECTED?
    • We may collect and process personal information about you in the following ways:
  • Information you give us.You may give us information about you by filling in forms on the Laduma VR application software (“App”) and/or any of our websites (“Our Sites”), or by corresponding with us by email, chat, telephone, or otherwise. This includes information you provide when you download or register the App, register to use Our Sites, access and use the App, subscribe to any of the services accessible through the APP (“Services”), search for the App or a Service, share data via the App’s social media functions, enter a competition, promotion or survey, and when you report a problem with an App, our Services, or Our Sites. The information you give us may include your name, address, e-mail address, phone number, Device’s phone number, age, username, password and other registration information, financial and/or credit card information, personal description, and photograph/s.
  • Information we collect about you and your Device.Each time you visit Our Sites or use the App we may automatically collect the following information:
  1. technical information, including the internet protocol (IP) address used to connect your computer to the internet, login information, the type of mobile device you use, a unique device identifier, mobile network information, your operating system and platform, the type of browser you use, browser plug-in types and versions, and time zone setting;
  2. information stored on your Device, including photos, videos or other digital content;
  3. details of your use of the App and your visits to Our Sites, including, but not limited to, traffic data, location data, weblogs and/or other communication data, whether this is required for our own billing purposes or otherwise, and/or the resources that you access;
  4. Use of GPS technology to access location information;
  5. Information we receive from other sources (Third Party Information).We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with certain third parties (including, for example, business partners, sub-contractors in technical, payment and/or delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  6. If you contact us, we may keep a record of that correspondence;
  7. Unique application numbers. When you 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.
  8. We may collect and store personal data on your Device using application data caches and browser web storage including HTML 5 and other technology.
  9. Personal Information. During or arising from certain commercial interaction/s with particular third parties, including, but not limited to, clients/customers/suppliers/subcontractors/service-providers/subscribers, we may deem it fit or appropriate or necessary to obtain, process, manage and/or store “Personal Information” on behalf of such third parties. “Personal Information” means information that relates, directly or indirectly, to an identified or identifiable person (a “Data Subject”), that may include names, email addresses, postal addresses, or online identifiers, which that party provides or submits to us. In accordance with our Data Protection and Privacy Processing Consent Notice (“Consent Notice”), we strive to ensure that such third parties freely and voluntarily consent for their personal data to be collected by any member of our staff for the purposes of concluding any applicable or necessary agreement/s, for promotional material and/or marketing, issuing quotes and/or processing or managing any aspect/s of our business relations with third parties or their organizations or any ancillary requirements connected to same. In many instances, such information comprises necessary contractual data in that some or all of the above details will be required when conducting business or for concluding contracts or issuing quotes/invoices or other necessary ancillary/related/connected documents.
  • HOW WE WILL USE INFORMATION ABOUT YOU
    • We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
  • Where we need to perform a particular contract which we have entered into with you;
  • Where we need to comply with a legal obligation; or
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and/or fundamental rights do not override those particular interests.

We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests); and/or
  • Where it is needed in the public interest (or for official purposes)
    • We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with certain legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties (such as marketing activity), provided your interests and/or fundamental rights do not override those interests.

In particular, the situations in which we will process your personal information may include:

  • Administering a particular contract that we have with you;
  • Business management and/or planning, including accounting and auditing;
  • To provide you, or allow third parties to provide you, with information, about our products or services including content and advertising tailored to your interests;
  • To send you marketing information from time to time. We will only contact you with information about our products and/or services which we think will be of interest to you. You have the right to object to us sending you this information at any time (please see below);
  • Dealing with any legal disputes we may have with you;
  • To notify you about changes to the App or any of the Services;
  • To ensure that content is presented in the most effective manner for you and your Device.
  • To comply with our legal obligations such as Health and Safety requirements;
  • To administer the App, Services and Our Sites, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To maintain, protect and improve the App, Services and Our Sites;
  • To allow you to participate in interactive features of the App and Services, when you choose to do so;
  • To ensure network and/or information security, including preventing unauthorised access to our computer and/or electronic communications systems and/or preventing malicious software distribution;
  • As part of our efforts to keep the App safe and secure.
    • We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
  • IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

If you fail to provide certain information when requested, we may not be able to perform the particular or applicable contract/s that we may have entered into with you (such as delivering goods and/or services to you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our customers / clients).

  • CHANGE OF PURPOSE
    • We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 
    • Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  • DATA SHARING
    • We may have to share your data with certain third parties, including third-party service providers (such as IT service providers).
    • We may also disclose your personal information to any member/s or affiliate/s of our group, which includes our subsidiaries, and our ultimate holding company and/or its subsidiaries, as defined in section 1159 of the Companies Act 2006.
    • We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
    • In the event that we sell or buy any business or assets, we may in such circumstances disclose your personal data to the prospective seller or buyer of such business or assets.
    • If Laduma Creative Enterprises Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    • Our third-party service providers and group members are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
    • In particular, we may also share your personal information with:
  • Appstore providers from whose site you downloaded the App;
  • Advertisers and/or advertising networks that require the data to select and serve relevant adverts to you and others;
  • Analytics and/or search engine providers that assist us in the improvement and optimisation of Our Sites;
  • Your mobile network operator;
  • Payment-processing services providers, in the event of purchases;
  • In order to:
    • enforce or apply our End User Licence, our Terms of Use and/or other agreements or to investigate potential breaches;
    • protect the rights, property or safety of Laduma Creative Enterprises Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and/or credit risk reduction.
  • WHERE WE STORE YOUR PERSONAL DATA.
    • The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us, our affiliates, or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and/or the provision of support services. By submitting your personal data, you specifically agree to this transfer, storing or processing.
    • We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
    • All information you provide to us is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. 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.
    • Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App or Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
  • DATA SECURITY
    • We have put in place measures to protect the security of your information.
    • Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
    • We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in any unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and/or other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
    • We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
  • DATA RETENTION
    • We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    • To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
    • In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
    • We will retain and securely destroy your personal information in accordance with applicable laws and regulations.
  • YOUR RIGHTS IN CONNECTION WITH PERSONAL INFORMATION
    • Under certain circumstances, by law you have the right to:
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
    • If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at [email protected]
  • NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded, unreasonable, or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

  • WHAT WE MAY NEED FROM YOU
    • We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
    • In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please do so in writing or contact our Chief Technical Officer via email on [email protected]
    • Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
    • Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and/or 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/or location data. Please check these policies before you submit any personal data to these websites or use these services.
  • CHANGES TO PRIVACY POLICY

Any change/s we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

  • CONTACT

Questions, comments and/or requests regarding this privacy policy are welcomed and should be addressed to support[email protected]