Sunderland App Privacy Policy
Last updated February 2024
Introduction
This privacy policy ("Policy") explains when, why and how personal information is collected, used and disclosed by Sunderland City Council (“Sunderland City Council ”, “we”, “us”) with respect to your access and use of this mobile application which is owned and operated by Sunderland City Council except where this Privacy Policy expressly states otherwise, Sunderland City Council is the controller of your personal data.
For the purposes of this Policy, "personal data" or "personal information" refers to personal data as defined by the Data Protection Laws (defined below), and includes any data that relates to you (such as your name, address, email address or device information that could identify you) and which is processed (i.e., stored, used, etc.) by Sunderland City Council as described more particularly in the section entitled "What Personal Information Do We Collect?" below). We process personal data only in compliance with applicable data protection laws, including the UK Data Protection Act 2018, the Irish Data Protection Acts 1988 to 2018, the EU General Data Protection Regulation (2016/679) (the "GDPR") and any legislation that replaces or supersedes them (together, the "Data Protection Laws").
What Personal Information Do we Collect?
The personal data we collect from you might include your:
What Personal Information Do we Collect?
The personal data we collect from you might include your:
- Name;
- Email address;
- Password which has been hashed and salted
- OAuth Identifiers from their respective providers if used.
- Mobile number if provided.
- Device Token used for sending notifications
- Anonymised diagnostic information for system maintenance
- Your location data, to enable location based services (where available)
- Information you provide us relating to your interests and preferences and other information relating to you that you choose to provide to us.
Except as described in this Privacy Policy, we do not generally ask you to disclose any sensitive information (e.g., medical information, details of race, religious or political beliefs, data concerning sexual orientation or sex life or membership of a trade union, or genetic or biometric data) to us. If we do ask you to provide us with any sensitive information, we will normally ask for your explicit consent in order to process this information.
If you do not provide your personal data to us, we may be unable to provide services to you, and you may not be able to create an account, or use the mobile application.
How will We Collect this Personal Information?
Information that you provide to us
We collect personal information from you when you:
- create an account and profile on our mobile application
- select interests and preferences within your account profile;
- complete a survey;
- participate in a contest or other promotion; or
- contact us through email, or otherwise communicate with us.
Information collected by automated means
We also obtain some of your personal information by automated means when you visit our mobile application, the geographical location of your device if consent is granted, even when the app is closed or not in use.
How Do We Use the Personal Information We Collect?
If you are a user of the mobile application:
If you use our mobile application (in this section, "mobile application User" or "you"), we will use your personal information in the following ways.
We may process the following personal information relating to Mobile Application Users | We may process Mobile Application Users' personal information for the following purposes: | What is the legal basis for us processing Mobile Application Users' personal information in this way: |
---|---|---|
Name Email address Password which hashed and salted Notification preferences Interest preferences you tell us about Geolocation data you share with us |
To set up and manage your mobile application account (for example, to send password reminders or notifications of changes to your account details). | Your personal information will be processed in this way where this is necessary to fulfil an account creation with you or to take steps at your request prior to such a contract being concluded. |
To keep you informed about What’s On and Incentives, (offers and discounts) linked to your marketing preferences. | It is necessary for us to keep records of your
notification preferences to comply with requirements of direct
marketing laws to which we are subject. We will ask for your consent to process your information in this way where this is required by applicable laws. |
|
To contact you when necessary or appropriate (for example to respond to your emails, submissions, questions, comments, requests, and complaints | ||
To ensure that we do not contact you if you have asked us not to. We understand that you may prefer for us not to contact you with details of our events or offers and discounts . We keep records of your notifications preferences in order to do this. | ||
To send you promotional materials, including newsletters and push notifications, about events and offers and discounts offered by third party organisations | ||
To offer you opportunities to participate in competitions or surveys operated by us or third party organisations. | ||
You have the right to opt out from these promotional messages at any time. For more information, see the section titled "Your right to withdraw consent to processing" below. | ||
Anonymised Diagnostic information | To diagnose and fix technical issues which may occur during the operation of the mobile application |
Who Do We Share Your Information with?
We will not share the personal information we collect from you through our mobile application, except as described in this Policy, or as required by law.
Where do we store your personal information?
The data we collect from you is stored in the United Kingdom . We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this this Policy and applicable data protection laws.
Links to Other Sites
Our mobile application provides links to external websites. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party's privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Website.
How long do we keep your personal information?
Your personal information is stored by us and/or our service providers and suppliers, only to the extent and for the time necessary to achieve the purposes for which the information is collected, in accordance with the Data Protection Laws. When we no longer need to use your information for these purposes, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
Your Choices and Privacy Rights
You have the following rights in connection with our processing of your personal data. If you wish to exercise one or more of these rights, please contact us with your request at Cityapp@sunderland.gov.uk.
Your right to access the information we hold about you
You may request access to the personal data we hold about you. Our file of your information will usually be made available to you within 30 days, although occasionally we may not be able to give you access to all the personal data we hold about you. For example, we may not be able to give you access if the information we hold includes both your personal data and the personal data of others and disclosing their information to you would adversely affect their rights.
Please note that if you request a copy of your data using electronic means (such as email), then we will provide a copy of your information in electronic form unless you ask us to do otherwise.
Your right to have your information corrected
You have the right to have incomplete or inaccurate personal information that we process about you rectified. Note that you can always make certain adjustments to certain personal information directly through your online account.
Your right to have your information deleted
You have the right to request that we delete personal information that we process about you. This right applies only in certain circumstances. For example, we are not obligated to delete your data where we need to retain it in order to comply with our legal obligations or to establish, exercise or defend legal claims.
Your right to object to us processing your personal data
Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
Your right to withdraw consent to processing
If you have consented to us processing your personal data for a particular purpose, you have the right to withdraw your consent at any time, free of charge, by contacting us. This includes cases where you wish to opt out from marketing messages that you receive from us (including marketing messages that we send on behalf of third party organisations). You can unsubscribe from marketing communications at any time by accessing the ‘Setting’ option in your account profile. If you withdraw your consent to processing, we may still contact you in connection with your account, and communications with us.
Your right to have an electronic copy of your personal data transmitted (right to data portability)
Where we hold personal data about you with your consent or for the performance of a contract with you, you also have the right to ask us to provide you with the personal data we hold about you in a structured, commonly used and machine-readable format and, where technically feasible, to transmit that personal data to another organisation.
Your right to restrict processing of your data
You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
Your right to lodge a complaint with the local data protection authority
You have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.
If you are based in the UK, the Information Commissioner's Office can be contacted as follows:
Telephone: +44 0303 123 1113
E-mail: casework@ico.org.uk
Website: www.ico.org.uk
Web-form: www.ico.org.uk/concerns/
Address: Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF
In Ireland, the Data Protection Commission can be contacted as follows:
Telephone: +353578684800
Website: https://dataprotection.ie/
Web-form: https://forms.dataprotection.ie/contact/
Postal Address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28,
Ireland
If you are based elsewhere in the European Economic Area (EEA), please use this link for a list of local data protection authorities in the EEA countries in which we operate: https://edpb.europa.eu/about-edpb/board/members_en .
Amendments to this Policy
This Policy may be modified from time-to-time. If we make changes to this Policy, we will notify you of these changes by email and post an alert on our mobile application.
Queries, Comments and Complaints about our Handling of Personal Information
If you have any questions, comments or complaints about our collection, use or disclosure of personal information, you wish to ask us to stop processing your personal information, you would like to request a copy of the personal information we hold about you, or if you believe that we have not complied with this Policy or the Data Protection Laws, please contact us by email at Cityapp@sunderland.gov.uk
We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may reasonably request.
You may also contact our Data Protection Officer, using the contact details below.
Email: data.protection@sunderland.gov.uk
Phone: 07769 672633