RESTLESS DEVELOPMENT – PRIVACY POLICY

1. OUR APPROACH TO PRIVACY
   1. Restless Development, a registered charity under charity no. 1127488 ("Restless Development", "we", "our" or "us"), is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you or your child ("personal information").
   2. Restless Development operates a platform, which we make available via the Restless Development mobile application that you can download on your device (the "App") and our website (available at https://www.trithisathome.co.uk/ (our "Site")), that allows users to sign up for, and submit information about their performance of, different physical challenges that can be completed in the user's own time for fun and to help raise money for young people and communities affected by COVID-19 (the "TriThisAtHome Service").
   3. This "Privacy Policy" sets out how we collect, store, use and disclose your personal information when you use the TriThisAtHome Service. Please ensure that you have read and understood this Privacy Policy before accessing or using the TriThisAtHome Service.
2. WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION

Restless Development is the controller of the personal information we hold about you in connection with your use of the TriThisAtHome Service. This means that we determine and are responsible for how your personal information is used.

3. PERSONAL information we collect FROM you when you use the TriThisAtHome Service, and how we use it
   1. We collect personal information about you and your child that you voluntarily submit directly to us when you use the TriThisAtHome Service. This can include information you provide to us through the TriThisAtHome Service, when you set up an account on the TriThisAtHome Service, when you add your children's information to your account, correspond with us by e-mail or otherwise, subscribe to our mailing lists or other forms of marketing communications, when you report a problem with the TriThisAtHome Service or use some other feature of the TriThisAtHome Service.
   2. The information we collect from you in this way will be:
      1. your contact information, such as your name and email address;
      2. information you submit when setting up a profile for yourself, such as username, password and profile picture, or when you set up a profile for your child, such as their name and profile picture;
      3. information about your or your child's activity on the TriThisAtHomeService, such as the challenges you or your child sign up for and your completion of those challenges;
      4. chat, comments and opinions that you send to us when you contact us directly;
      5. information received from JustGiving about your donations; and
      6. any preferences you set in the TriThisAtHome Service.
   3. We will indicate to you where the provision of certain personal information is mandatory. If you choose not to provide such personal information, we may not be able to provide those parts of the TriThisAtHome Service to you or respond to your other requests.
   4. The table at Annex 1 sets out in detail the categories of personal information we collect and how we use that information when you use the TriThisAtHome Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
   5. By providing data through this app, you are consenting to its processing by Restless Development in accordance with our privacy policy and the GDPR. Your data will be stored securely on European based servers, and will only be processed by connection to the 'TriThisAtHome' event - including public use of you and your child's name, photograph and challenge totals, as well as use within the app. Find more information in Annex 1 and in Restless Development's privacy policy. 
4. Information we collect about you automatically
   1. We also automatically collect personal information indirectly about how you and your child access and use the TriThisAtHome Service, and information about the device you use and allow your child to use to access the TriThisAtHome Service. For example, we may collect:
      1. information about the features you use and the pages you view;
      2. information about your device (such as your IP address, device identifier, device type, model and manufacturer); and
      3. information about your usage patterns (such as how often you use the TriThisAtHome Service and your language settings).
   2. We use this information to provide you the features and functionality of the TriThisAtHome Service, to monitor and improve the TriThisAtHome Service and to develop new products and services.
   3. The table at Annex 2 sets out in detail the categories of personal information we collect automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information.
   4. We may link or combine the personal information you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
   5. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you or your child). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the TriThisAtHome Service and developing new products and features. We may also share such anonymised and aggregated information with others.
5. How long will we store your personal information
   1. We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, and in any event for no longer than 12 months after you delete your account on for the TriThisAtHome Service, in accordance with our legal obligations and legitimate business interests.
   2. We may, however, need to retain your personal information for longer if we are required to do so by law.
6. RECIPIENTS OF PERSONAL INFORMATION
   1. We may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
      1. Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.

We have listed examples of specific service providers that we use in Annexes 1 and 2.

6. 1. 2. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
      3. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Restless Development, its users or others.
7. Marketing and Advertising
   1. From time to time we may contact you with information about our products and services and the products and services of our partners, including sending you marketing messages.
   2. We will only send you marketing emails if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by emailing us at trithisathome@restlessdevelopment.org.  
8. Storing and Transferring your Personal Information
   1. Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your credit or debit card information or national identification numbers.
   2. International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are accessing the TriThisAtHome Service from the European Economic Area ("EEA"), your personal information may be processed outside of the EEA.
   3. In the event of such a transfer, we ensure that: (i) the personal information is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.
   4. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.
9. Your control over your information
   1. You may review and edit some of the personal information you have submitted to us (such as yours or your child's name and profile picture) through the appropriate functionality in the App settings.
10. Your rights in respect of your personal information
    1. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
       1. Right of access. You have the right to obtain:
          1. confirmation of whether, and where, we are processing your personal information;
          2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
          3. information about the categories of recipients with whom we may share your personal information; and
          4. a copy of the personal information we hold about you.
       2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
       3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
       4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
       5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
       6. Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
    2. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
    3. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
    4. You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available here.
    5. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
11. COOKIES and similar technologies
    1. Our Site uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users. Cookies are pieces of code that we transfer to your computer's hard disk for record-keeping purposes. This helps us to provide certain functionalities of the TriThisAtHome Service, to provide you with a good experience and also allows us to monitor and analyse how you use and interact with the TriThisAtHome Service so that we can continue to improve the TriThisAtHome Service.
    2. We use the following types of cookies:
       1. Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
       2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the TriThisAtHome Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.  
       3. Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org.

11. 3. Please see Annex 3 for more information about the specific cookies we use on the TriThisAtHome Service.
    4. The cookies we use are designed to help you get the most from the TriThisAtHome Service but if you do not wish to receive cookies, most browsers and devices allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of the TriThisAtHome Service. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.
       1. Cookie settings in Internet Explorer
       2. Cookie settings in Firefox
       3. Cookie settings in Chrome
       4. Cookie settings in Safari web and iOS.
    5. For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like Restless Development. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’.
    6. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
12. Tracking Technologies used in our emails
    1. Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
    2. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.
    3. Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.]
13. LINKS TO THIRD PARTY SITES
    1. The TriThisAtHome Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
14. OUR POLICY TOWARDS CHILDREN
    1. We do not actively allow children under the age of 16 to register to use the TriThisAtHome Service. Parents or legal guardians must register with the TriThisAtHome Service to allow their child to use the TriThisAtHome Service.  If you become aware that your child has signed up to the TriThisAtHome Service and provided us with personal information without your approval, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
15. CHANGES TO THIS POLICY
    1. We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
16. NOTICE TO YOU
    1. If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by a notification within the App. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
17. CONTACTING US
    1. Please contact trithisathome@restlessdevelopment.org if you have any questions, comments and requests regarding this Privacy Policy.
    2. This Privacy Policy was last modified on Friday 26th June 2020.