Privacy Policy and Cookie Policy

WeShareApps operating as WeShareApps.com values your privacy and is committed to protecting it. This Privacy Policy outlines how we gather, utilize, share, and safeguard your personal information, commonly referred to as personal data. Additionally, this policy informs you of your rights and options regarding your personal information and provides guidance on how to reach us for any inquiries you might have.

By creating an account or engaging with any WeShareApps website, application, product, software, tool, data source, or service (collectively referred to as the 'Service'), you acknowledge and accept the terms defined in this policy.

This Privacy Policy details how we collect, use, disclose, retain, and protect your personal information. We encourage you to read it carefully.

Applicability of this Privacy Policy

This Privacy Policy applies to users of WeShareApps services globally, including those using WeShareApps mobile applications, partner platforms, websites, features, and other services, as well as any interactions (whether online or offline) with Digiterra, comprising employees and job applicants (collectively referred to as the 'Service').


This document specifies how WeShareApps collects and processes data and applies to all users worldwide, unless covered by a distinct privacy notice for certain services. It particularly pertains to:

  • End Users: Individuals who directly use and interact with the Services through their WeShareApps account for personal purposes.
  • Business Users: Entities supplying us with personal information regarding their end customers in relation to their activities, either directly or indirectly.
  • End Customers: Individuals benefiting from services requested by other WeShareApps account holders, such as conducting transactions with a business user.

How We Collect, Disclose, and Use Personal Information

We obtain information about you through various methods based on your interactions with us and our services, including:

Direct Collection

Information you provide when creating an account, subscribing to communications, placing orders, making purchases, or contacting us by phone, email, or other means.

Automatic Collection

Data collected through cookies, server logs, and similar technologies while interacting with our Services and/or emails, where permitted by law or with your consent.

Third-Party Sources

Information sourced from affiliates, business partners, service providers, online social networks, or publicly available data. For instance, if you apply for a job, we may perform a background check.

WeShareApps as Data Controller


WeShareApps takes on the role of data controller by defining the purposes and means of processing personal data. Our responsibilities include:

Direct Registrations: WeShareApps is the data controller when users register directly for our services, applicable in both B2C and B2B contexts.

Key Activities

  • Provision of Services: Utilizing data to provide Digiterra products and services.
  • Fraud Prevention: Monitoring and detecting fraudulent transactions.
  • Legal Compliance: Adhering to requisite financial, legal, and regulatory obligations.
  • Service Improvement: Enhancing product offerings based on data analysis.
  • Job Application Processing: Handling personal data related to job applications.


WeShareApps as Data Processor

In certain cases where we provide services on behalf of business users, WeShareApps functions as a data processor, which involves:

B2B Configurations: Acting as a data processor concerning data related to end customers from business users.

Service Execution: Carrying out directives from business users, such as account creation and distribution to end customers.

As a data processor, we recommend that users review the privacy policies of the relevant data controllers (business users) for details on how their data is processed and protected. Digiterra is committed to following the instructions given by data controllers while ensuring the confidentiality and security of the processed data in compliance with applicable data protection regulations and contractual responsibilities.


Information We Collect

The following are examples of the types of information we collect across various contexts and the purposes for which we utilize that information.

ContextData TypesPrimary Purpose of Data Collection and UseAccount RegistrationWe collect your name and contact details, including your email, upon account creation. Additionally, we gather information regarding your actions while logged into your account.Our legitimate interest lies in providing account-related functionality to users. Accounts streamline the checkout process and enable us to save preferences and transaction histories. This information may also be processed to fulfill our contractual obligations to you.Biometric InformationWe collect biometric identifiers from ID photos and selfies.We process biometric data only with your explicit consent to verify your identity through the eKYC process as required by law.Business UsersWe gather name and contact details, such as email, phone number, and postal address, of employees from our business clients.Our legitimate interest is in maintaining effective communication with our customers concerning standard business operations, including projects, services, and billing.Necessary Online Tracking TechnologiesWe utilize cookies and clear GIFs. 'Cookies' are small data files sent to your computer by a website you're visiting, while clear GIFs are pixels loaded by your browser upon website access.These tracking technologies may collect details regarding your browser type, operating system, IP address, domain name, click activity, referring website, and/or date/time stamps. Our legitimate interest is to ensure the efficient operation of our website.Non-Essential Tracking TechnologiesWe may employ additional tracking technologies such as cookies or pixels that gather statistics and monitor user interactions with our website or facilitate behavioral advertising.These tools may also compile information regarding your browser type and other engagement metrics across multiple sites. We utilize third-party cookies based on consent where required by law.Demographic InformationWe gather personal information, for example, your age or location.Understanding our user demographic is aligned with our legitimate interest in delivering personalized services.Job SeekersIf you apply for a position or become an employee, we collect the necessary information for processing your application or employment, including contact details, educational background, and work history.Our legitimate interest involves evaluating candidates for potential employment. In some cases, we are legally required to collect specific applicant information to ensure compliance.Comments/HelpWhen providing feedback or reaching out for support, we collect your name, email address, and any additional information you provide.We have a legitimate interest in addressing your feedback or inquiries effectively.Mobile DevicesWe collect unique identification data from your mobile device when you access our website.We have a legitimate interest in recognizing unique visitors and tracking visits to enhance our website's functionality.Placing OrdersUpon placing an order, we gather your name, billing and shipping addresses, email address, phone number, and credit card information.This information is crucial for fulfilling our contractual obligations to provide you with our services.Promotion of PartnersInformation you provide during brand promotions with other companies may be collected.We have a legitimate interest in conducting promotional activities effectively.SurveysIf you participate in a survey, we collect the information you provide. If the survey is managed by a third party, their privacy policy governs the data handling.Our legitimate interest is in obtaining insights into your opinions and gathering relevant information for our organization.

We keep your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including any legal, accounting, or reporting obligations, unless a longer retention period is mandated or allowed by law. To ascertain the appropriate retention duration for personal data, we take into account the volume, nature, and sensitivity of the information; the potential risks of harm from unauthorized use or disclosure; the reasons for collecting the information and whether those objectives can be met through alternative means; as well as applicable legal standards.

How We Use Personal Information

  • To identify you during your visits to our websites.
  • To provide products and services or process returns.
  • To enhance our services and product offerings.
  • To streamline and optimize the payment process.
  • To perform analytical studies.
  • To communicate with you, including responding to your inquiries, questions, or comments.
  • To send promotional and marketing materials related to our products, services, sales, or promotions, including those from our business partners.
  • To detect and protect against malicious, deceptive, fraudulent, or illegal activities, including breaches of our policies and terms, security incidents, and threats to the rights, property, or safety of our company or others.
  • To debug, identify, and repair issues that hinder the proper functionality of our website and services.
  • To comply with our regulatory or legal obligations, assert or exercise our rights, and defend against legal claims.
  • For internal administrative tasks and relationship management.
  • For any other purposes to which you may consent from time to time.


How We Share Personal Information

Acquisitions: Should another company acquire or intend to acquire our company, business, or assets, we will also share information with them, even at the negotiation stage.

Disclosures Without Your Consent: We may disclose information in response to subpoenas, warrants, or court orders, as part of any legal proceedings, or to comply with relevant laws. We may also share your information to protect our rights, defend against legal claims, investigate, prevent, or take action regarding suspected illegal activities, fraud, safety concerns, or policy violations, or to fulfill requests for product delivery or services provided by third-party intermediaries.

Partner Promotions: If we offer promotions in collaboration with third-party partners, your information may be shared with both us and the partner if you choose to participate. How they use your information will not be governed by this Privacy Policy.

Service Providers: We may share your information with service providers that assist us in managing our website and efficiently conducting our business, including those providing technical support, processing payments, and fulfilling orders.

Other Consensual Disclosures: We may disclose your information to third parties with your consent or at your direction.

Your Rights

Depending on your location and in accordance with applicable law, you hold the following rights:

  • Access to Your Data: You have the right to request disclosure of the personal information we collect, use, or disclose about you, along with details on our data practices. Under certain circumstances, you may also request access to your personal information in a portable, machine-readable format.
  • Verification and Rectification: You can request corrections to your inaccurate personal information. We rely on you to keep your information current. Our website allows you to modify or delete your account profile. If certain changes cannot be made via our website, please contact us to request modifications. Note that we may retain historical data in our backup files as legally permitted.
  • Deletion of Personal Information: You can request the deletion of your personal information that we have collected.
  • Withdrawal of Consent: You may withdraw your consent at any time, where you previously provided it for us to process your personal information.
  • Objection to Processing: You have the right to object to the processing of your personal information if the processing is based on grounds other than your consent.
  • Online Tracking: Currently, we do not recognize the 'tracking signal.'


It's important to note that not all rights are absolute, and certain limitations may apply. In some situations, we might limit or refuse your request, as permitted or mandated by law, or if we cannot adequately verify your identity. We will not discriminate against individuals exercising their privacy rights as outlined in applicable law.

For more details regarding your specific rights, please read this section carefully. To exercise any of the rights mentioned, or to dispute a decision made regarding your request, please reach out to us using the contact information provided below

As required by law, we will need to verify your identity before processing your request. Depending on the nature of your request, we may request information such as your name, the last item you purchased, or the date of your last transaction, and you might be asked to provide a signed statement confirming your identity. After receiving your request, we will make every effort to facilitate the correction or deletion of your personal data from our records.

In specific situations, you may appoint an authorized agent to submit requests regarding your privacy rights on your behalf. If you are an authorized agent acting on behalf of another individual, you must include a signed document confirming your authority to represent them.

How to Unsubscribe from Marketing Emails?

You can opt out of receiving marketing emails by utilizing the unsubscribe feature found in your Profile Settings. To manage your preferences, log into your account and navigate to your Profile Settings. Toggle the option for 'I want to receive promotional emails' to on or off to save your changes. Your email address will be promptly opted out of marketing communications.

For inquiries about how to unsubscribe from marketing communications, please feel free to reach us at info@weshareapps.com

How to Delete My Account?

You may delete your account by using the 'Delete Account' option located in your Profile Settings. After logging into your account, go to your profile settings, click on the 'Delete Account' button, and confirm your decision. We will process your request promptly or within one month if special circumstances apply.

Please keep in mind that we may have to verify your identity and your relationship with us before proceeding with your request.

When Does WeShareApps Continue Processing Data After a Deletion Request or Objection?

In specific cases, Digiterra might be legally required to retain and process your personal data even after a deletion request or an objection is submitted. For instance, we are obligated to keep certain personal information in accordance with legal requirements related to Know Your Customer (KYC) and payment transaction details.

Data Transfer and International Data Transfer

The Service is operated by Digiterra, which may be accessible in Europe and other countries. As such, your information may be processed in a jurisdiction where privacy laws might not be as stringent as those in your home country. Nevertheless, we will take measures to ensure personal information is treated according to the same privacy principles that apply under the laws of the jurisdiction from which we first received your information. By providing your personal information to us, you consent to its transfer, storage, and processing in countries outside of your residence, including but not limited to the United States. For more information regarding our efforts to maintain applicable privacy principles across different jurisdictions, please reach out using the contact information below.

Security

We adhere to widely accepted standards to protect your personal information. However, no method of transmission over the internet, mobile technology, or electronic storage is completely secure. Therefore, while we strive to maintain physical, electronic, and procedural safeguards to ensure your information's confidentiality online, we cannot guarantee its absolute security.

As a WeSahreApps user, you are responsible for maintaining the security of your password and credentials. If you suspect that your interaction with us has become insecure (for example, if you believe your account security has been compromised), please notify us immediately at info@weshareapps.com.

Changes to This Policy

We reserve the right to modify the terms of this Privacy Policy at any time. Should we make any significant changes either to this statement or to the way we utilize your personal information, we will notify you by posting a notice on this page or our home page or by sending you an email. We encourage you to review this policy regularly whenever you visit one of our websites or applications. Our Privacy Policy includes an 'effective date' and a 'last updated' date. The effective date refers to when the current version comes into effect, while the last updated date indicates when significant modifications were last made.

Minors

Our Services are not designed for children under the age of 13, and we do not knowingly collect personal information from minors under the age of 16 without parental consent. Children younger than 13 should not provide us with any personal data.

Contact Information

If you have any questions, comments, requests, or complaints regarding our privacy practices, or if you require this Privacy Policy in an accessible format due to a disability, please contact us at the address provided below. We will strive to respond to your inquiry and furnish you with additional details about our policy.


Email: info@weshareapps.com


If you are dissatisfied with our response and reside in the European Union or the United Kingdom, you may have the right to file a complaint with your local supervisory authority.


User Terms and conditions

Please read these terms and conditions ("Terms", "Terms and Conditions") carefully before using the http://www.weshareapps.com website (the "Service") operated by WeShareApps ("us", "we", or "our")

Your access to and use of http://www.weshareapps.com and the Service is conditioned on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Service.

By accessing or using http://www.weshareapps.com and the Service you agree to be bound by these Terms. If you disagree with any part of the terms then you may not access the Service.

Using and Downloading

General

After you order an application (“App”) and pay the listed price, a copy of the App may be downloaded for your personal use.

Trial Access to Apps

Free trial and other limited versions of apps may be offered, in order for you to preview Apps before purchasing the full version. These free trials may contain limited features, time restrictions on usage, and other limitations.

In-App Products

There may be offered products within the downloaded Apps. The third-party developer sells these products and WeShareApps has no responsibility for the functions of these products and/or applicable terms and conditions. WeShareApps is not a party to any In-App purchases and have no responsibility for any transactions you make through an App.

All sales final

All purchases of Apps from WeShareApps are final. We do not accept returns of Apps. Accordingly, a right of withdrawal does not cover the supply of digital content that is not supplied on a tangible medium if the performance has begun with the consumer's prior express consent and acknowledgement that he thereby loses his right of withdrawal. Once you have purchased an App from WeShareApps, you are encouraged to download and access the App promptly to ensure you have received it. Once the App has been made available to you, your bear responsibility for completing the download. You bear the risk for all losses after downloading, including any losses due to a device malfunction.

Downloading and availability of Apps after purchase

You may download copies of the App for your personal use, after your purchase. While we usually will continue making Apps you have purchased available to you, so that you may download additional copies for your personal use, under the terms of these Terms and Conditions, we may in some cases limit or discontinue any further downloads of an App, due to licensing restrictions or for other reasons. Some Apps are reliant on cloud-based services provided by the publisher. Should the publisher discontinue these services, the App may not function properly.

Licenses

By purchasing the App, you are granted a, non-exclusive, irrevocable, non-sublicense able and non-transferable license. You may only use the App for personal use. You may not, modify, transfer or sell the App or anything that grants any party other than you access to the App.

Updates to Apps

The App-publisher may provide updates to the third party App. These updates may be automatically installed to your Apps or you may be prompted to install these updates.

Third Party Apps

WeShareApps allows you to obtain Apps that have been developed by a third party. The terms and conditions governing your use of any third party App, even if you obtained the App through WeShareApps, will be those that are provided by that third party and will govern your use of that third party App. The terms and conditions required by the third party App licensor are those you must agree to, be bound by and comply with, if you wish to use their App. WeShareApps has no liability or responsibility for the Apps content and functionalities, your use of the App, the consequences of your use of that App and/or otherwise arising from that App or your agreement or relationship with the third party provider of that App.

Accounts

When you create an account with us, you must provide us information that is accurate, complete, and current at all times. Failure to do so constitutes a breach of the Terms, which may result in immediate termination of your account on our Service.

You are responsible for safeguarding the password that you use to access the Service and for any activities or actions under your password, whether your password is with our Service or a third-party service.

You agree not to disclose your password to any third party. You must notify us immediately upon becoming aware of any breach of security or unauthorized use of your account.

Privacy

WeShareApps respects your privacy and we will not access any information that is not relevant to the performance and download of the Apps. Notwithstanding the aforementioned, your use of WeShareApps may make certain information, including personally identifiable information, including location data, available to us and our operational service providers, sponsors, marketing and promotional partners and others. By using WeShareApps you are consenting to and approving the collection, storage, processing, transmittal, use, disclosure and sharing of your information. We reserve the right to monitor your use of WeShareApps to ensure compliance with these Terms and Conditions and laws and regulations applicable to your use of it.

Links To Other Web Sites

Our Service may contain links to third-party web sites or services that are not owned or controlled by WeShareApps.

WeShareApps has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that WeShareApps shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services.

We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.

Termination

We may terminate or suspend access to our Service immediately, without prior notice or liability, for any reason whatsoever, including without limitation if you breach the Terms.

All provisions of the Terms that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

We may terminate or suspend your account immediately, without prior notice or liability, for any reason whatsoever, including without limitation if you breach the Terms.

Upon termination, your right to use the Service will immediately cease. If you wish to terminate your account, you may simply discontinue using the Service.

All provisions of the Terms that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

Changes

We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will try to provide at least 30 days notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Service.

Disputes

Consumer complaints regarding WeShareApps may be submitted to info@weshareapps.com. Read more on the rights to complain, amount limits, fees, the process etc. here:

Governing Law

These Terms shall be governed and construed in accordance with the laws of England and Wales, without regard to its conflict of law provisions.

Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights. If any provision of these Terms is held to be invalid or unenforceable by a court, the remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements we might have between us regarding the Service.

Force Majeure

WeShareApps will not be liable for delays in performance or for non-performance due to unforeseen circumstances or causes beyond WeShareApps reasonable control.

DISCLAIMING WARRANTIES & LIABILITY

WESHAREAPPS IS PROVIDED “AS IS” AND “AS AVAILABLE” AND WE MAKE NO REPRESENTATIONS OR WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, TITLE, NON-INFRINGEMENT, FITNESS FOR A PARTICULAR PURPOSE OR OTHERS UNDER THE LAWS OF ANY JURISDICTION. YOU BEAR THE SOLE RISK ASSOCIATED WITH THE APP AND YOUR USE OF THE APP. YOU APPRECIATE THE APP MAY NOT MEET YOUR, OR ANY SPECIFIC REQUIREMENTS, NOR DO WE GUARANTEE UNINTERRUPTED OR ERROR FREE USE. ANY USE, DAMAGE, MODIFICATION OR OTHER CHARACTERISTIC OF CONTENT OR SOFTWARE OR OTHER MATERIAL, TANGIBLE OR INTANGIBLE, THAT YOU USE, DOWNLOAD, ACQUIRE, TRANSMIT OR PROCESS USING THE APP IS DONE SOLELY AT YOUR RISK AND WE WILL NOT BE LIABLE OR RESPONSIBLE FOR ANY DAMAGE TO YOU OR ANY PERSONS OR PROPERTY, INCLUDING, WITHOUT LIMITATION, CONTENT, SOFTWARE, DATE OR YOUR DEVICE, RELATED TO YOUR USE OF THE APP. SOME JURISDICTIONS DO NOT PERMIT THE DISCLAIMER OF CERTAIN IMPLIED WARRANTIES, SO SOME OF THESE DISCLAIMERS MAY NOT APPLY TO YOU. IN NO EVENT SHALL WE BE LIABLE FOR DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, PUNITIVE, SPECIAL OR CONSEQUENTIAL DAMAGES, REGARDLESS OF THE FORM OF ACTION OR BASIS OF THE CLAIM AND YOUR EXCLUSIVE REMEDY AND OUR SOLE LIABILITY IN CONNECTION WITH THE APP, YOUR USE OF WESHAREAPPS AND ANY OTHER CLAIM OR ACTION ARISING FROM THE APP, YOUR USE OF THE APP OR THESE TERMS AND CONDITIONS, IS TO REFUND ANY LICENSE FREE OR PRICE YOU PAID FOR THE APP. THE LIMITATION OF LIABILITY REFLECTS THE ALLOCATION OF RISK BETWEEN THE PARTIES AND WILL SURVIVE; PROVIDED, HOWEVER, THAT SOME JURISDICTIONS DO NOT ALLOW CERTAIN LIMITATIONS OF LIABILITY, SO SOME OF THESE LIMITATIONS MAY NOT APPLY TO YOU.

Data protection policy

Context and overview

Key details

  • Policy prepared by: Anders Juhl CEO
  • Approved by board / management on:WeShareApps
  • Policy became operational on:24/05/2018
  • Next review date:24/05/2020

Introduction

WeShareApps needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures WeShareApps:

  • Complies with data protection law and follow good practice
  • Protects the rights of staff, customers and partners
  • Is open about how it stores and processes individuals’ data
  • Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations — including WeShareApps— must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

  • Be processed fairly and lawfully
  • Be obtained only for specific, lawful purposes
  • Be adequate, relevant and not excessive
  • Be accurate and kept up to date
  • Not be held for any longer than necessary
  • Processed in accordance with the rights of data subjects
  • Be protected in appropriate ways
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

  • The head office of WeShareApps
  • All branches of WeShareApps
  • All staff and volunteers of WeShareApps
  • All contractors, suppliers and other people working on behalf of WeShareApps


It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • …plus any other information relating to individuals

Data protection risks

This policy helps to protect WeShareApps from some very real data security risks, including:

  • Breaches of confidentiality. For instance, information being given out inappropriately.
  • Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  • Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with WeShareApps has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

  • The board of directors is ultimately responsible for ensuring that WeShareApps meets its legal obligations.
  • The [data protection officer], Anders Juhl, is responsible for:
  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data [company name] holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  • The [IT manager], Anders Juhl, is responsible for:
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
  • The [marketing manager], Anders Juhl, is responsible for:
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

  • The only people able to access data covered by this policy should be those who need it for their work.
  • Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
  • WeShareApps will provide training to all employees to help them understand their responsibilities when handling data.
  • Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
  • In particular, strong passwords must be used and they should never be shared.
  • Personal data should not be disclosed to unauthorised people, either within the company or externally.
  • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
  • Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

  • When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  • Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

  • Data should be protected by strong passwords that are changed regularly and never shared between employees.
  • If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
  • Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
  • Servers containing personal data should be sited in a secure location, away from general office space.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  • Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  • All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to WeShareApps unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

  • When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  • Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
  • Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
  • Personal data should never be transferred outside of the European Economic Area.
  • Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires WeShareApps to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort WeShareApps should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
  • Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
  • WeShareApps will make it easy for data subjects to update the information WeShareApps holds about them. For instance, via the company website.
  • Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
  • It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by WeShareApps are entitled to:

  • Ask what information the company holds about them and why.
  • Ask how to gain access to it.
  • Be informed how to keep it up to date.
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at [email address]. The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, WeShareApps will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

WeShareApps aims to ensure that individuals are aware that their data is being processed, and that they understand:

  • How the data is being used
  • How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

Contact Us

If you have any questions please contact info@weshareapps.com.

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