We're Where You At Ltd., with registered office at 124 Finchley Road, London, England, NW3 5JS (referred to as 'WYA', 'We', 'us' or 'our'). We are registered with the ICO with registration number ZB597253. WYA has designed an app to address the safety of people and avoid dangerous situations at events and in nightclubs. We want people to have fun - to avoid people spending nights out anxiously looking for friends when they should be spending time with them.
This policy was last updated on 20th September 2023.
How do you use my data?
- When you download and use our App using your WYA credentials or via single sign on, we collect personal information provided by you such as your name, username, e-mail, phone number, location, friends list, user device ID while using our app. We only process your personal data via our App if you have given us your consent to do so. We use your personal data to create and store your profile preferences and provide you access to the information the App has recorded about you, such as your location history in one of the venues that has implemented Bluetooth beacons (see below).
Our App WYA uses Bluetooth beacons to allow you to find friends, even when you are offline. You can search for them on a map or send them an message if needed. You can also send the SOS to the venue to alert the venue. Our Bluetooth beacons form a mesh network across the venue where they are installed. By combining this network with floor plans provided by the venue, WYA can create highly accurate maps of different event venues, and where you and your friends are, to help you find them. We use your data in this way based on your consent.
- To send you marketing information. Where you have previously expressed an interest in our services (and not opted-out of marketing) we will use your name and email address to send you updates because it is in our legitimate interests to promote our other products and services we think you might be interested in.
Where you are a new customer and have opted in via our registration page to receive updates on our and/ or third party products and services including offers, promotions and new options, we will process your personal data to provide you these updates in line with the preferences you have provided and will only use your personal information in this way with your consent.
You can withdraw your consent to marketing at any time by contacting us at firstname.lastname@example.org or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.
- When you contact us either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
- When you attend one of our events or a third-party events or promotions (including virtual events via video conferencing providers including Zoom), we will usually collect your name, address, email address and phone number. We collect this information because it’s in our legitimate interests to promote our business and to know who’s attending our events.
- If our business is sold. We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.
Who do you share my data with?
- Venues who implement Bluetooth beacons are able to see anonymised data on how many people using our app were in a specific location, and how they moved around the building.
- Business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you.
- Promotional events and marketing organisations, we do not sell your personal data for marketing purposes, but may share your anonymised, aggregated data with an event organiser or collaboration brand.
- Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.
Where do you store my data?
We store your data on third-party servers which are based both in the UK and outside of the UK.
When working with third parties we may need to transfer your personal data outside of the UK and/or EU.
Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at email@example.com for more detail on this.
How long do you keep my data for?
We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
We delete your customer account 6 years after you last used our app. Other information related to your account, such as your location and venue history, will be deleted 2 years and 1 month after your account has become inactive.
In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.
What are my rights under data protection law?
- Access your personal data (also known as a “subject access request”);
- Correct incomplete or inaccurate data we hold about you;
- Ask us to erase the personal data we hold about you;
- Ask us to restrict our handling of your personal data;
- Ask us to transfer your personal data to a third party;
- Object to how we are using your personal data;
- Withdraw your consent to us handling your personal data.
You also have the right to lodge a complaint with us or the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU you can find your relevant supervisory authority here.
Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.
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