Shoal Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY REGISTERING FOR AN ACCOUNT OR BY ACCESSING OR USING THESE SERVICES, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY AND ALL TERMS INCORPORATED BY REFERENCE. IF YOU DO NOT AGREE TO ALL OF THESE, DO NOT ACCESS OR USE THE THESE SERVICES.

This Privacy Policy (together with our Terms and Conditions and any other documents referred to on it describes how Shoal Community LTD, registered in Scotland under company number 5274951, 6 Yardheads, Edinburgh EH6 6BU (“Shoal Community LTD”, “Shoal”, “we’, “us”) will process any personal data we collect from you, or which you provide to us, in the course of using Shoal Together (the “App”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. When this policy mentions “Shoal,” “Shoal Together,” “we,” “us,” or “our,” it refers to Shoal Together Ltd, the company that is responsible for your information under this Privacy Policy (the “Data Controller”).

THE INFORMATION WE COLLECT

Information that you Give to us

When you access the App or use our Services, there are a number of ways in which we may ask you to provide information and other data to us. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services. You may be asked to provide us with the following personal information: 1) your full name, 2) email address, 3) address, 4) telephone number, 5) job title, 6) industry, 7) languages, 8) social media details, 9) date of birth, 10) emergency contact, 11) home descriptions, 12) travel history and plans and 13) other interests and self-descriptions you choose to provide. By accessing the App, you consent to us processing and collecting this data, on the terms and for the reasons which are explained below.

We may also collect and process the following data about you:

  • Information you put into forms or surveys on our site at any time;
  • A record of correspondence between us;
  • Details of transitions you carry out through our website and app;
  • Details of your visits to our website and app and the resources you use;
  • Information stored on mobile devices, such as photos, calendar information and contacts;
  • Information about you from other Shoal users, such as trust ratings, friend connections, public references, and other interconnections and interactions;
  • Location Information;
  • Device Information: we may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information and information about the device’s interaction with our Services.
  • Log Information: We collect log information about how you access or use our Services, including your access times, browser type and language, Internet Service Provider and Internet Protocol (“IP”) address.
  • To use certain features of the Shoal Platform (such as booking or becoming a Host), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Stripe Payments).
  • Information Collected by Cookies and other Tracking Technologies: We may automatically collect information using cookies, web beacons (also known as “tracking gifs,” “pixel tags” and “tracking pixels”) and other tracking technologies to, among other things, improve our Services and your experience, monitor user activity, count visits, understand usage and campaign effectiveness, and tell if an email has been opened and acted upon. For information about removing or rejecting cookies, please see “Your Information Choices” below.
  • We may also obtain information from other sources and combine that with information we collect through our Services. For example, if you create or log into your Shoal account through a third-party social networking site, we will have access to certain information from that site, such as your name, profile picture, connections and other account information in accordance with the authorisation procedures determined by such third-party social networking site.
  • Some of this information may be shared with other users, for example they may be able to see your connections who are also Shoal users. Please see “Your Information Choices” below for more information about how to manage your sharing preferences.

Information You Choose to Give Us

You may choose to provide us with additional personal information in order to obtain a better user experience when using Shoal platform. This additional information will be processed based on your consent.

  • Additional Profile Information. You may choose to provide additional information as part of your Shoal profile (such as gender, preferred language(s), city, and a personal description). Some of this information will become part of your public profile page, and will be publicly visible to others.
  • Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, participate in promotions, or use other features of the platform.

HOW YOUR INFORMATION IS USED

As is true of most Apps, it will be possible to gather information about your computer or device such as your IP address, browser type, referring/exit pages, and operating system. This information may be used to:

  • Information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu;
  • Drive future product development in line with customer platform and technology use;
  • Protect the safety of Shoal users and provide our verification service;
  • Monitor and analyse trends, usage and activities in connection with our Services;
  • Respond to customer service requests;
  • Send out a newsletter or occasional product alerts or marketing communications;
  • Improve the App and our marketing efforts; and/or
  • Link or combine with other information we get from third parties to help understand your needs and provide you with better service
  • Respond to your questions and concerns.

Certain features of the App (such as uploading or downloading content) may need to access information on your computer or device in order to work. By using such functionality, you consent to Shoal Community LTD accessing your device and information. If we can, we will ask you before the App accesses your device or information.

HOW TO EDIT, DELETE OR ACCESS YOUR INFORMATION

You have the right to ask for a copy of any personal information that we hold about you, to correct any inaccuracies and to update any out-of-date information. You can also ask us not to send you direct marketing communications (however please note that we may continue to send you service-related (i.e. non-marketing) communications whilst you hold an account with Shoal Community LTD. If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at [email protected]

SHARING YOUR INFORMATION

Except as described below, we will not share your information with any third parties.

We may disclose the information you provide us:

  • to any of our group companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985);
  • as required by law, any applicable regulation to protect the rights, property, or safety of ourselves or others. This may include disclosing to other companies and organisations in connection with fraud protection and credit risk reduction;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • if Shoal Community LTD is involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets. You will be notified via email and/or a prominent notice on our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;
  • to any other third party with your prior consent to do so.

We will never pass your information to a third party for them to use in their own direct marketing without your express consent.

Please note that if you click on, or follow, any links from the App to external Apps, our privacy policy will no longer apply. Please check the privacy policies of any such external App or app before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.

SOCIAL MEDIA TOOLS

We may offer social sharing features or other integrated tools which let you share actions you take on our Services with other media, and vice versa. The use of such features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features. Shoal may also allow you to access Google Maps. Please note that when you use Google Maps, you are subject to Google’s privacy policy, as amended by Google from time to time.

SECURITY

The security of your personal information is important to us. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. We will retain your information for as long as your account is active or as needed to provide you services via the App. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer hold your personal information, contact us at [email protected]

INTERNATIONAL TRANSFERS

Information we collect may be transferred to, stored and/or processed in any country or territory where one or more of our partners or third party service providers (for example, our hosting company) are located or maintain facilities, including destinations outside the European Economic Area (“EEA”). While other territories may not have the same standards of data protection as those within your home country, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. By submitting your personal data, you you agree to such transfers, storage and or processing in other territories.

CONTACTING YOU

We may contact you from time to time about the App, including marketing messages relating to the App. We will do this electronically, for example by email, text, or by telephone.

We may contact you with information about our products and services (and those of specially selected parties that may be of interest to you, in line with your marketing contact preferences provided to us either through the App or by emailing us. All such communications will come from Shoal Community LTD.

You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at the email below or by following any instructions we may include in the messages we send to you.

USE OF COOKIES AND OTHER INFORMATION

The App uses cookies and similar technologies (‘cookies’) when you create an account, to authenticate you when you use the service, and to generally improve your experience on the App. By using the App, you accept our use of cookies as set out here. We use these cookies to collect information about your use of the App, for example, which areas you use most often and if you receive any error messages. This information helps us improve performance and your user experience and to develop our products and services for you and other users. This information may also be used to help us provide more meaningful and relevant communications to you.

USE OF LOCATION DATA

The App may make use of location data sent from your mobile device. You can turn off this functionality at any time by turning off the location services settings for the App on your mobile device. If you use these services, you consent to us and our partners’ and licensees’ transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services. You may withdraw this consent at any time by turning off the location services setting on your mobile device or on the App.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the App prior to the change becoming effective. We encourage you to periodically review the App for the latest information on our privacy practices. This Privacy Policy and all changes made hereto as described in the previous paragraph remains effective unless and until we inform you otherwise via a push notification through the App, through email (sent to the e-mail address specified in your account) or by means of a notice on our App prior to the expiration of this Privacy Policy.

CONTACT

If you have any questions or comments about this Privacy Policy, you can contact us by email at the following email address: [email protected] You can also use this address if you wish to request a copy of the personal data we hold about you.