Privacy Policy

 Privacy Notice

The purpose of this notice

Thank you for downloading our Rate Your Leader (RYL) app. This privacy notice explains how we will process your personal data if you use our app, whether you are a voter or a leader. Our use of your personal data is subject to the EU General Data Protection Regulation and other relevant UK and EU legislation (together Data Protection Legislation). It is important that you read it, so that you are fully aware of how and why we are using your data, and what data protection rights you have.

What does this notice cover?

Who we are

When we say we, us or our in this privacy notice, we mean Rate Your Leader Limited, a company incorporated and registered in England with company number 11246547, and whose registered office is at The Sunderland Software City, Tavistock Place, Sunderland, United Kingdom, SR1 1PB.

For the purposes of the Data Protection Legislation, we are the controller of your personal data. This means that we are responsible for deciding how we hold and use personal information about you.

Our Data Protection Officer is Joel Popoola. You can contact me at enquiries.app@rateyourleader.com.

Personal data we use

Personal data means information which relates to an identified or an identifiable individual. We may collect, use, store and transfer various types of your personal data as set out in the table below:

Type of app users

Types of personal data

Examples

Voters

Identity data

Title; first name; last name; gender; date of birth; photographs;

Contact data

Residential address; email;

IT data

Your user ID and encrypted password to our RYL app; and

Your activity data

Questions to leaders which you submit through our RYL app; posts which you upload onto our RYL app (such as your comments to our blog articles).

Leaders and candidate leaders

Identity data

Title; first name; last name; gender; photographs;

Contact data

Official email address;

IT data

Encrypted password to our RYL app;

Public profile data

Political manifestos; campaign promises;

Voter generated data

Questions submitted to you by your voters through our RYL app; Voters’ ratings of your responses to their questions; and

Your activity data

Your responses to the voters’ questions submitted through our RYL app; Your newsfeeds posted through our RYL app on your voters’ RYL timelines.

Political opinions (purpose). Political opinions are classed under the Data Protection Legislation as special categories of data. Such data can be lawfully processed, if certain conditions are met. Our RYL app is a messaging platform designed to help voters to engage with their elected leaders and leader candidates within their constituencies. If you are a voter, it will enable will enable you to take more active part in your local community. If you are a leader or a candidate leader, it will help you to directly reach and better understand your electorate and the key issues and concerns they may have.

Political opinions of voters’ (lawful basis). The questions, posts, responses and comments which you choose to submit through our RYL app, may include your political opinions. If you are a voter, we will process such data based on your permission. You can withdraw your consent at any time by emailing us at enquiries.app(at)rateyourleader.com.

Political opinions of leaders’ (lawful basis). If you are a leader or a candidate leader, any responses to voters’ questions, newsfeeds or other posts which you will choose to submit through our RYL app will be treated as disclosed into the public domain on the basis of substantial public interest. Any other information containing your political opinions which we may use in our RYL app (for example, your or your party’s political manifestos or campaign promises), will be data which had previously been made public.

Profiling. We allow leaders registered with our app to publish news feeds on the RYL profile timelines of selected registered voters. Such voters are selected automatically based on the target characteristics chosen by the leader (for example, post code, age, gender). We do that to enable leaders to reach with their messages voters to whom such messages are relevant. You have the right to object profiling for marketing purposes. For more details, see the Your rights section of this privacy notice.

Anonymised data. We may also collect, use and share anonymised, aggregated data such as statistical or demographic data for any purpose. Anonymised data may be derived from your personal data but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate information on how you use our website to calculate the percentage of users accessing a specific website feature.

Children. We do not knowingly process personal data of children. If you believe that we have received information relating to or from persons under the age of 18 please contact us at enquiries.app@rateyourleader.com. If we become aware that a person under the age of 18 has provided us with personal information we will take steps to delete such information.

Before you disclose personal data to us

Before you disclose to us the personal information of another person you must ensure that you have a lawful basis to do so (for example, you have that person’s permission, or the information is sourced from the public domain).

For guidance on when and how you can lawfully disclose personal data, please see the Information Commissioner’s Office Guide to the General Data Protection Regulation. [insert as link to: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/]

How we collect personal data

We collect most of this information from you direct. However, we may also collect information from other sources.

Type of source

Examples

Directly from you

when you register to use our RYL app; sign up to our mailing list; submit any questions, responses, posts, news feeds or ratings to our RYL app;

From publicly accessible sources

if you are a leader or a candidate leader, we will source information about you (e.g. your official email address and your campaign promises) from public domain sources (e.g. your official public profile);

Your usage of our RYL app

we will collect information generated through your usage of our RYL app (e.g. questions and responses you voted on);

Directly from a third party

if you are a voter we will obtain confirmation that you are on the relevant electoral roll from credit reference agencies; and

Automated technologies or interactions

as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns.

How and why we use personal data

Under the Data Protection Legislation, we can only use your personal data if we have a proper reason for doing so. For example, because: you have given us your consent; or it is necessary for the performance of a contract; or it is necessary for our legitimate interests or those of a third party; or it is necessary for performance of our legal obligations.

Consent (voters’ data). If you are a voter, we rely on your consent to process questions, posts, responses and comments which you choose to submit through our RYL app. We process such information to enable you to engage with your elected leaders and leader candidates within your constituency. You can withdraw your consent at any time by emailing us at enquiries.app@rateyourleader.com. When you withdraw your consent we may anonymise and continue using some of such information.

Contract (voters’ and leaders’ data). We process your information to enable you to use the features of your RYL app and to provide user support.

Legitimate interests (voters’ and leaders’ data). Using your data for a legitimate interest means that we have a valid reason to use your information, so long as this is not overridden by your own rights and interests. We rely on our own, and/or or a third party’s legitimate interests, when we process your data for the following purposes:

  • to promote the culture of direct connectivity between voters and elected leaders (or candidate leaders);
  • to filter inappropriate content (for example, abusive comments);
  • to analyse, improve and promote our RYL app;
  • to create statistics based on anonymised and aggregated data (for example, the number of voters engaging with their elected leaders through our RYL app per each constituency);
  • if you are a voter, to authenticate your details against the relevant electoral roll;
  • if you are a voter, to enable your elected leaders or candidate leaders to post news feeds on your RYL profile timeline;
  • if you are an elected leader or a candidate leader, to provide voters with information about you which are relevant to the public function which you hold or wish to be elected for (for example, your performance against your campaign promises); and
  • for security and the prevention and detection of fraud.

Legal obligation (voters’ and leaders’ data). We may process your personal data to comply with our legal obligation. For example, to: notify you about changes to our terms or privacy policy; address your complaint; or comply with a request from a competent authority.

Who we share personal data with

Data sharing. We may share your information with third parties for the purposes set out in this notice. For example, we may:

  • share your personal data with our suppliers which we use to operate our business (for example Google for the purpose of hosting our RYL app or MongoDB who supply the database program used by our RYL app);
  • [share API with Know Your Customer’s Companies, The Election and Commissioners];
  • disclose your personal data to professional advisers (e.g. lawyers, accountants, auditors or insurers) who provide professional services to us;
  • disclose and exchange certain information with law enforcement agencies and regulatory bodies to comply with our legal obligations; and
  • share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

International transfers. We do not transfer your personal data outside the European Economic Area.

How long we keep personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

If you are a voter, we will only retain your personal information for as long as you are a registered user of the RYL app. We will delete your personal information when: there is no justification for its further retention; or you have asked us to delete it. We may keep anonymised information (for example statistics and aggregated data which do not identify you) indefinitely without further notice to you.

If you are an elected leader or a candidate leader, we will retain your personal data for as long as it is necessary for the purposes set out in this privacy notice. We may keep some data for longer for archiving purposes in the public interest and for historical purposes. We may also keep anonymised information (for example statistics and aggregated data which do not identify you) indefinitely without further notice to you.

Your rights

Data protection rights. You have a number of rights in relation to your personal data, which allow you to access and control your information in certain circumstances. You can exercise these rights free of charge, unless your request is manifestly unfounded or excessive (in which case we may charge a reasonable administrative fee or refuse to respond to such request).

Your right

Explanation

Access

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Rectification

The right to require us to correct any inaccuracies in your personal data.

Erasure (to be forgotten)

The right to require us to delete your personal data in certain situations.

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances (e.g. if you contest the accuracy of the data we hold).

Data portability

The right to receive, in certain situations, the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party.

To object

The right to object at any time to your personal data being processed for direct marketing (including profiling) or, in certain other situations, to our continued processing of your personal data (e.g. processing carried out for the purpose of our legitimate interests).

Not to be subject to automated individual decision-making including profiling

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you, or similarly significantly affects you.

How to make a data protection request? If you would like to exercise any of those rights, please contact us at enquiries.app@rateyourleader.com. Please let us know what right you want to exercise and the information to which your request relates.

For further information on your rights, please see the Information Commissioner’s Office Guide to the General Data Protection Regulation. [insert as link to: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/]

Keeping personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully.

Complaints

We will do our best to resolve your complaint. We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information. You may contact our Data Protection Officer by email at enquiries.app@rateyourleader.com 

Your right to complain to the ICO.

The Data Protection Legislation also gives you a right to lodge a complaint with a supervisory authority, in particular in the European Union (or the European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws has occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/make-a-complaint/ or by telephone on: 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office, so please contact us in the first instance.

How to contact us

If you have any questions about this privacy notice, (including any requests to exercise your legal rights) please contact our Data Protection Officer by email at enquiries.app@rateyourleader.com.

Changes to this privacy policy

This privacy policy was last updated on [17 December 2018].

We may change this privacy notice from time to time, when we do we will publish the new version of the policy on our RYL app. We may also inform you via email.