Privacy Policy

Please read this Privacy Policy carefully before using our Platform and/or Services.

You should also read our Terms & Conditions, Platform Acceptable Content Use Policy and Cookie Policy.

Our privacy policy

We are committed to protecting and respecting your privacy and personal data, and will only collect and use personal data in ways described here and consistent with our obligations and your rights under applicable law.

This Privacy Policy aims to give you information about how we collect and process your personal data when you visit our websites and applications (together, the “Platform”), register to use our Services, or otherwise interact with us.

By using our Platform and/or Services, you agree to be bound by this Privacy Policy and consent to the collection, use, processing and disclosure of your personal data as described here.

Who we are and how to contact us

This Platform is operated by Generation App Ltd, a company registered in England and Wales with company number 14900573 and registered office at L39, 39th Floor, One Canada Square, Canary Wharf, London E14 5AB (“GenFam”, “we”, “us” or “our”). We are the controller and are responsible for our Platform.

We are registered as data controllers in England and Wales, and our Information Commissioner’s Office (ICO) registration number is ZB956072.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at [email protected]. Our Data Protection Officer can be contacted at [email protected].

What personal data we collect about you

Personal data means any information about you that enables you to be identified personally. Depending on how you use our Platform, we may collect, use, store and transfer different kinds of personal data, grouped as follows:

• Identity Data — name, username, gender, date of birth, marital status, title and photographic/facial identification data.
• Contact Data — residential address, billing address, delivery address, email address and telephone numbers.
• Financial Data — bank account and payment card details.
• Transaction Data — details about payments to and from you and Services purchased.
• Technical Data — IP address, login data, browser type and version, time zone, location, operating system and platform.
• Profile Data — username and password, purchases or orders, interests, preferences, feedback and survey responses.
• Usage Data — information about how you use and interact with our Platform and/or Services.
• Marketing and Communications Data — your preferences in receiving marketing and your communication preferences.

How we collect your personal data

• Direct interactions — when you enter information on our Platform, create an account, fill in forms, subscribe to communications, or correspond with us.
• Automated technologies — as you interact with our Platform we may automatically collect Technical Data using cookies, server logs and similar technologies.
• Third parties or publicly available sources — such as analytics providers, search information providers, and platforms including Facebook, Meta, Google and Apple.

Purposes for processing personal data

We will only use and process your personal data when the law allows us to. Most commonly we use it: to perform a contract with you; to comply with a legal or regulatory obligation; where it is necessary for our legitimate interests (and your rights do not override those interests); or where you have provided your consent.

We use your personal data to register you as a user, manage your access to the Platform, personalise your experience, administer and protect our business, respond to your queries, supply information you have requested, improve our Platform through analytics, and process orders and payments.

Marketing

We may send you marketing communications by email, text message, telephone or via the Platform. We will obtain your express opt-in consent before sharing personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time. Opting out will not affect service-related communications that are essential for administrative or customer service purposes.

How we may share your personal data

We may share your personal data with professional advisors, regulators and authorities, and service providers we work with, including:

• Google Analytics — for marketing and advertising services.
• Google — including Firebase Cloud Messaging and Google Maps Platform, for push notifications, maps and related services.
• Amazon Web Services (AWS) — for cloud hosting and storage, including S3.
• Apple — for “Sign in with Apple” and other authentication or platform services.
• Meta (Facebook) — where you use Facebook login or related integrations.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those who have a business need to know.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so.

How we will retain your personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the data, the potential risk of harm, the purposes of processing, and applicable legal requirements.

International transfers

Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it, either by transferring only to countries deemed to provide adequate protection, or by using specific contracts approved for use in the UK and/or EEA.