Scope of this Policy
We are TheTriangleLab Limited (Dojo, we, us, our), the company behind the Dojo service (Service). The Service is designed as an online and Smartphone application (App) providing location-based recommendations for services, products and venues including restaurants, bars and events. The individual or organisation that subscribes to the Service will be referred to as the “Subscriber” or “you”.
For the purposes of the General Data Protection Regulation, we are the data controller.
If you contact Dojo by e-mail, we may keep a record of your correspondence or comments. We may ask for your name, e-mail address and contact information in order to send you a reply.
Third party information and links
Information may be sourced from third parties by Dojo and/or you in compiling the Service. Where such third party information forms or may form part of the Service, we have relied on the information provided to us by third parties. We do not guarantee the correctness or completeness of the information provided on the Service.
Sharing directly with third parties
You and other Subscribers may share content on the Service via a number of social media platforms (including, without limitation, Facebook, Twitter, Google+) and email. When content is shared in this way a link to that content is sent out via the relevant social media channel.
Please be responsible with personal information of others when using Service. We are not responsible for your misuse of Personal Information, or for the direct relationship between you and others when takes place outside of the Service.
Personal Information we may collect about you
We will collect any information that you provide to us when you:
The information you provide to us will include (depending on the circumstances):
We also collect the following information about you when you use the Service:
Purposes for which Dojo uses Personal Information and Recipients of your Personal Information
We will use your information for the purposes listed below either on the basis of:
Where we use your information for our “legitimate interests”, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights to your Personal Information”
Dojo uses Personal Information provided by Subscribers and accessed by the Service for the purposes of:
Except in relation to certain selected partner websites, Dojo will not permit your Personal Information to be used for direct marketing purposes.
In connection with the purposes and on the lawful grounds described above, we will share your Personal Information when relevant with third parties such as:
There may be limited circumstances in which Dojo is obliged to disclose Personal Information to unrelated third parties such as:
Dojo will fully co-operate with law enforcement, investigation and security agencies and regulators to identify anyone who uses the Service or software for illegal activities. Dojo reserves the right to report to law enforcement, investigation and security agencies and to regulators any activities that are believed to be unlawful.
Storage (including international transfers outside of the EEA), Security and Retention of Personal Information
Personal Information that Dojo collects is stored on its servers (which may be cloud-based and located outside the EEA). We implement and maintain adequate security measures to protect such information stored on our servers and seek to comply with all local rules in respect of storage of data.
Whenever we transfer Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:
Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use such as:
Dojo also strives to collect no more Personal Information from end-users than is required for the purpose for which it is collected. This, in turn, helps reduce the total risk of harm should data loss or a breach in security occur. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it, For example,
Help keep your information safe
You can also play a part in keeping your information safe by:
Dojo does not seek to collect “sensitive” Personal Information 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) Dojo does not wish to receive any such data and will not request it. If Subscribers voluntarily post such information on the Service or share it with other Subscribers, the Subscriber assumes the risk of such information being accessed, used or distributed by others as such information has been manifestly made public by the Subscriber.
Data on children Persons under the age of 16 should not transfer Personal Information to us unless they have the consent of their parent(s) or guardian(s). We do not knowingly collect, nor do we want to receive, personal information about individuals who are under 13 years of age. If you are under the age of 13, please do not access our Service at any time or in any manner. We will take appropriate steps to delete the Personal Information of persons under the age of 13.
Your Rights to your Personal Information
From 25 May 2018, in accordance with new data protection laws which will be in force from that date, you will have certain additional rights in respect of the information that we hold about you, including:
What we need from you to process your requests
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will need to have created an account in order for us to provide you with your information because without an account, we are not able to connect your data to a verifiable email address.
From 25 May 2018, 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your use of the Service. You may change the Personal Information that Dojo retains about you by accessing the Service and following the instructions.
You may unsubscribe from the Service at any time. When you unsubscribe from the Service (or when it is otherwise terminated) we will permanently and irretrievably delete all Personal Information we hold on your behalf, save that:
(1) copies of your Personal Information may remain stored for limited periods of time on back-up media which shall be cleansed from time to time;
(3) Dojo shall be entitled to retain any data in Generic Data obtained from your Personal Information.