Privacy Policy

Introduction

Fika is committed to protecting and safeguarding your personal data. As part of this commitment, we’ve created our privacy policy to meet the high standards of the new European data protection law, known as the General Data Protection Regulation (GDPR).

This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

We value your privacy and Fika’s position as a safe place for real talk. The data we collect as outlined below helps to ensure Fika can operate, we can maintain the service, and we can improve the service for our Members. And importantly, we can also take necessary measures to protect our Members.

Within each Fika your privacy is respected, subject to the Terms of use. Fika does not monitor chat sessions, record or store the spoken contents of a Fika. Fika (chat and voice) sessions are between Members only and subject to Fika’s Terms of use.

Important information and who we are
The data we may collect about you
How your personal data is collected
How we will use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Fika collects and processes your personal data through your use of this Service (by way of website, application or other form) (“Services”), including any data you may provide through the use of Fika Services.

This Service is not intended for any persons under 18 years of age and we do not knowingly collect data relating to persons under 18 years of age.

Controller

Fika Community Limited is the controller and responsible for your personal data (collectively referred to as ”COMPANY”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our details are:

Post:: Fika Community Limited, Challenge House, Sherwood Drive, Milton Keynes, MK3 6DP.
Email:: hello@fika.community

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This policy was last updated on 13th November 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we may collect about you

Personal data, or personal information, means any information about an individual from which that person can be directly or indirectly identified. It does not include data where the identity has been removed (anonymous data).

Fika is committed to maintaining privacy and not exploiting individual Personally Identifiable Information – information from which an individual can be directly identified (PII). As standard the only PII Fika captures is email address and phone number. However, under certain circumstances we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1: Identity Data: Includes first name, last name, username or similar identifier, title, date of birth, age consent (over 18). Please note: any identity data will not be shared with, or made available to, other members during your Fika. This identity data relates to your registration, access to the service and 3rd party services such as financial processors.
2: Contact data: Includes billing address, email address and telephone numbers.
3: Financial Data: Includes bank account and payment card details.
4: Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us.
5: Technical Data: Includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Service. This data is used to monitor, debug and improve the service.
6: Profile Data: Includes your username and password, purchases or orders made by you, your Fika topics, interests, preferences, feedback, survey responses, forum submissions, Fika exercises selected, messages and Preference Selection Image Choosing Interface (‘image selections’) – includes your image selections made whilst using the Service.
7: Usage Data: Includes information about how you use our Service, products and services.
8: Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, email or through use of the Service.

This includes personal data you provide when you:

Apply for our products or services;
Create an account on our Service;
Use the Service
Request a Fika (chat or voice session); or
Give us feedback.

Referrals

We may have received your data from a Third Party as someone who may be interested in the Service. This also includes an existing user of the service recommending you as someone who may be interested in the Service.

Automated technologies or interactions

As you interact with the Service, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

Usage patterns: We use mobile analytics software to allow us to better understand the performance of our Services. This software may record information such as how often use the Service, the events that occur within the application or services, aggregated usage, performance, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the service.
Log Data and IP address: The servers that run our Services create standard log files about your activity. These logs record visitor activity and information about your device, such as the browser you’re running, and the pages you access. This information helps us diagnose server and software errors. We gather certain information and automatically store it in log files. This information may include internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. If you receive email newsletters, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These are used to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.

Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources who may act as data processors as set out below:

Technical Data from third party data processors;

Such as Cloudinary, OneSignal, Mixpanel, Sendgrid, Google, Apple, Twilio, VoxImplant and MailChimp based outside the EU.

Media and Communications networks who may act as data processors;

Such as The Tab Media Ltd based inside the EU.
Such as Facebook, Instagram, SnapChat and Google based outside the EU.

Search Information providers;

Such as Google and Microsoft based outside the EU.

Contact, Financial and Transaction Data from third party data processors who are providers of technical, payment and delivery services; networks who may act as data processors;

Such as Stripe, Google, Apple, MailChimp based outside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we need to contact you to discuss your interest in, joining Fika.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing hello@fika.community.

Purposes for which we use your personal data

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose / Activity

1: Register you as a new Fika Community member (a ‘Talker’ & ‘Listener’):
Type of data

A: Identity
B: Contact
C: Technical

Lawful basis for processing including basis of legitimate interest
Performance of contract with you. For example, when you create an account, you will be asked to enter your phone number and email address. We will send you a confirmation email and text message to verify the account. We record the IP address used when you register for an account. We use this to ensure that user accounts are legitimately created by a human and not by script.

2: To process and deliver you services including:
A: Recommending Fika friends, arranging Fikas and connecting you into a Fika (chat or voice) with a ‘Member’, as a ‘Talker’ or ‘Listener’ and to deliver the Fika service overall.
B: Managing payments, fees and charges
C: Collecting and recovering money owed to us
D: Collecting and profiling your ‘image selections’, Fika requests and feedback responses to improve your user experience through compatibility matching.

Type of data
A: Identity
B: Contact
C: Financial
D: Transaction
E: Marketing and Communications
F: Profile

Lawful basis for processing including basis of legitimate interest
A: Performance of a contract with you
B: Necessary for our legitimate interests (to recover debts due to us)

3: To manage our relationship with you which will include:
A: Notifying you about changes to our terms or Privacy Policy or Terms of Use
B: Asking you to leave a review or take a survey
C: Managing member access in accordance with the service Terms of use

Type of data
A: Identity
B: Contact
C: Profile
D: Marketing and Communications

Lawful basis for processing including basis of legitimate interest
A: Performance of a contract with you
B: Necessary to comply with a legal obligation
C: Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
D: Necessary to manage and moderate member access to the service in accordance with the Service Terms of use

4: To administer and protect our business and this Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data):

Type of data
A: Identity
B: Contact
C: Technical
D: Profile

Lawful basis for processing including basis of legitimate interest
A: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
B: Necessary to comply with a legal obligation

5: To deliver relevant Service content and communications to you and measure or understand the effectiveness of the communications we serve to you:

Type of data
A: Identity
B: Contact
C: Profile
D: Usage
E: Marketing and Communications
F: Technical

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

6: To use data analytics to improve our Service, products/services, marketing, customer relationships and experiences:

Type of data
A: Technical
B: Usage

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business and to inform our marketing strategy).

7: To make suggestions and recommendations to you about goods or services that may be of interest to you:

Type of data
A: Identity
B: Contact
C: Technical
D: Usage
E: Profile

Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)

Third-party marketing

We do not share your personal data with any third parties but we may share generalised data which is anonymous.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing us hello@fika.community or by following the unsubscribe link in our emails.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at hello@fika.community.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

8. Data retention

How long will you use my personal data for?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us – hello@fika.community.

In some circumstances, you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at hello@fika.community

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within 14 days. Occasionally it may take us longer than 14 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us on hello@fika.community.

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed

Data Processor means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External third parties

Service providers acting as processors based in the United Kingdom, European Union, United States and Indonesia who provide IT, technical development, system administration, payment, CRM and email, SMS and VoIP call services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in England & Wales who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personally identifiable data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can request erasure using the delete your account feature within the Fika app or by emailing hello@fika.community stating your request for erasure at any time, we will endeavour to reply to you with 5 working days.

Erasure of data

Upon receipt of a data erasure request, Fika will delete the following personally identifiable information (PII) within 30 days:

Email
Mobile phone number
Any open and active chat sessions with other users will be closed and all messages sent to other users will be deleted.
We may also capture if relevant other PII data such as: name, age, gender and address, in such cases where these are known, they will also be deleted.

Fika will retain the following information that has already been submitted into the community, that is not classified as, does not contain and cannot be linked to any individual (PII – Personally Identifiable Information).

Any image choices made whilst using the service
Any Fika exercises or topics selected
Any records of usage patterns or behaviour amalgamated into a larger data set
Any data used for accounting or financial reporting purposes
Any data which we are required to retain by law, or where we detect misuse or harmful conduct by someone using the Service.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

hello@fika.community