Last updated: 28 July 2023
We understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who uses our App and plays our games and we will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
In this policy, “we,” “us,” and “our” means Six To Start Limited, a limited company registered in England under company number 06289098, whose registered address is Preston Park House, South Road, Brighton, East Sussex, UK, BN1 6SB.
1. About this Policy
This policy deals with where we are acting as a ‘data controller’ under the data protection legislation: which essentially means where we are responsible for deciding what personal information we collect and how we use it. When we refer to “personal information” we mean information relating to you personally or from which you can be identified. Some of the information mentioned in this policy is not ‘personal information’ as is meant under data protection legislation, but we may refer to it to help you understand what we do.
In this policy you will find information about what types of personal information we hold about you, how and why we collect it, how we use it, and how we keep it secure. You’ll also find information about your rights and how you can exercise them.
Please read this policy carefully and if you need to contact us about anything that is in here, or for anything else related to your personal information, you can reach us by email at firstname.lastname@example.org or by post at the address above.
2. What information do we collect about you?
We will collect some information about you to enable you to use the App, to improve or optimise your App experience, to provide user services, to improve the services we provide and for marketing (see below for more details). This may include:
- Your email address, password information;
- Your game profile needed for the App to function, such as, GPS run traces, game play/run logs (e.g. distance, time, date, speed etc) and in-game progress, achievements;
- Usage and telemetry data including information about how you use the App, and related services and technical information about the device you are using;
- IP address including rough physical location information.
We will never collect sensitive information about you without your explicit consent.
3. How we collect information about you
We will collect this information in a variety of ways depending on how we interact with you.
You may give us your identity, contact or other information by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use our products or services;
- interact with customer services;
- subscribe to our mailing lists;
- enter a competition, promotion or survey;
- register for alpha, beta or other early access to App features;
- give us feedback; or
- provide services to us.
Automated technologies or interactions
As you interact with the App we may automatically collect technical data about your device, in-App actions and patterns. We collect this personal data by using third party analytics software such as telemetry data, server logs and other similar technologies.
4. How we use your information
The information we collect about you will be kept secure by us in accordance with our obligations under the Data Protection Act 2018. The information we collect may be used by us to:
- to provide and manage the App and its related services;
- to plot run races using the GPS functionality of your mobile device however this information will remain accessible only to us unless you decide to share the data publicly via the App;
- to enable your use of the App and associated services;
- to open and run your user account and provide you with an up to date, efficient and reliable service;
- to monitor the use of the App;
- to monitor your contributions (if any);
- to answer your enquiries or deal with your complaints;
- account verification and clearance;
- displaying your in-game profile;
- displaying leader boards;
- to help us develop improve the App;
- detecting hacking, cheating and other activities that ruin the experience of players using the App;
- detecting and reporting fraud and other unlawful activity;
- direct marketing to let you know about App news and developments and products and services that may be of particular interest to you;
- managing competitions and/or promotions and your registration for the same;
- managing alpha, beta or early access tests including collecting your feedback;
- complying with legal or regulatory requirements; and
- to generate anonymous and aggregate data reports to highlight the use of the App for internal business purposes.
Integration of the App with Healthkit
If you choose to have ZRX integrate with HealthKit on your Apple product then the application will have access only to the health data types you explicitly opt-in to access.
ZRX requests permission to write certain data types into your HealthKit data store. These are used to record your running activities as measured by the App.
The data read from HealthKit is used solely within the App. It is not collected or disclosed outside of your local installation of the App. Only those data types in Healthkit relevant to the App are accessed. The data read is used to update and verify the running data saved to the HealthKit store.
In no case is your personal data from Healthkit transferred to a third party. It is only ever kept within the application container of ZRX or transferred to your personal HealthKit data store as per your permission choices.
WE WILL ONLY USE INFORMATION COLLECTED ABOUT YOU IN ACCORDANCE WITH THE DATA PROTECTION ACT 2018.
5. Legal basis for processing
There are a number of different legal grounds for processing personal information under the Data Protection Act 2018. Which one is applicable will depend on how we are using your information and for what purpose. In the majority of cases this condition will be that:
- you have provided your consent to us using your personal information in that way;
- our use of your personal information is in our legitimate interest as a commercial organisation. However, we will only use personal data relating to users for the purposes of legitimate interests where users’ interests, and rights and freedoms do not override our legitimate interests or the legitimate interests of the organisations we work with. Our legitimate interests include for the purpose of providing, developing, improving and promoting the App and our wider business;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation.
6. Sharing your information
The personal information you provide to us may be shared with our staff and the following types of third parties:
- platforms and distributors of our App such as Google Play and The App Store;
- service providers such as game back-end providers, data analytics providers, data storage providers, marketing partners, and customer service support partners;
- our auditors, insurers, lawyers and other professional advisers;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
- other wholly-owned subsidiary, sister or holding companies in our corporate group; or
- other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
User Profile Sharing
As part of the App, you may create your own profile showing your progress through the game, and also your runs and other data (including personal data) which you have submitted to us. The default setting of the App will not share this information with other users of the App or the general public, but you may opt to share this information with your friends and the general public.
You may also opt to share your information and use of the App on social networks such as Facebook and Twitter. You should check your privacy settings of those networks to ensure you are happy with the way your information is shared.
7. Marketing Communications
If you have agreed to be contacted for marketing purposes we may use your personal information to send you information about us and our services, such as future offers, events and new services or related activities that we believe you may find useful. You can unsubscribe from receiving them at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further such e-mail or other marketing communications from being sent to you by emailing email@example.com.
We will action any opt out request from you as soon as we can.
We will not send you any marketing emails or pass your information on to third parties unless you give your consent or you have given it already.
We will not share or use your health data with any third parties for marketing purposes.
Please note that if you are below the age of 16 you should not provide any personal data to us. If you older than 16 years of age, but below 18 years of age you should obtain the consent of your parent or guardian before you submit personal data to us. We not knowingly collect or use any personal data relating to children under the age of 16.
9. International transfers
We routinely transfer personal data outside the EEA. Where we transfer personal data outside the EEA to a country that has not been recognised as providing an adequate level of data protection, we use the standard contractual clauses unless we have identified another appropriate safeguard or relevant exemption.
10. Your Rights
If you believe we have information about you that you do not want us to have or that is incorrect please contact us as described below and we shall correct or remove the data as you request as soon as is reasonably practicable and/or provide details to you of how you can update the data.
Everyone has the right to:
- Information about how we use personal data (which is what this notice is for)
- Access to personal data
- Object to the use or disclosure of personal data for certain purposes
- Erasure of personal data
- Portability of personal data
- Withdraw consent where our use of personal data is based on consent
- Rectification of personal data
- Restriction of personal data
- Complain to your supervisory authority
Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant.
You will not be treated differently or discriminated against for exercising any of your rights.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Such measures will be appropriate to the nature of the data concerned and the level of risk. If you have been provided with a password to access any of our services you should not share that password with anyone else.
12. Terms of Service
13. Changes to this Policy
We may need to amend this policy from time to time, for example, in order to ensure that we remain compliant with applicable law or to reflect any changes we make to the App and its related services.
Your continued use of the App and its related services after any changes to the policy have been made by us will mean that you accept those changes. If you do not agree to any changes to the policy, you may not continue to use the App and its related services.
Any changes to this policy will not affect your accrued rights and will not have any retrospective effect.