Privacy Statement

October 2020

This Privacy Statement explains how Competitive Media Technologies Limited and the Compete group of companies (we refer to these as “Compete”, “we”, “us”, or “our”) collect, use, and share your personal information in connection with the website, application (including a mobile application), product, software, or service that links to this Privacy Statement (we call these our “Services”).

By using our Services, you agree to the collection of your personal information (described below) and to the terms of this Privacy Statement, including any updates or amendments thereto. Please consult this Privacy Statement regularly for changes, which may be made by Compete without notice and at any time.

IF YOU DISAGREE WITH THIS PRIVACY STATEMENT, YOU SHOULD DISCONTINUE USING OUR SERVICES.

Any images, videos or other content posted onto our Services becomes published content and is not considered personal information, subject to this Privacy Statement.

For California residents, please review our statement for California users under CCPA below, which we prepared in compliance with the California Consumer Privacy Act of 2019 (“CCPA”) (“California Statement”).

Who We Are and How to Contact Us:
Competitive Media Technologies Limited is a company incorporated in England and Wales (Company Number: 12033223) with registered office address at 10 Queen Street Place, London, United Kingdom, EC4R 1AG. Any comments, concerns, complaints, or questions regarding our Privacy Statement may be addressed to privacyteam@competeapp.net or you can write us as follows:

To the Compete Data Protection Officer at:

Data Protection Officer
Competitive Media Technologies Limited
10 Queen Street Place, London, United Kingdom, EC4R 1AG

Information Collection:
Certain features of our Services may require the submission of personal information. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our Services or respond to any queries you may have.

The type of personal information we collect depends on how you are specifically interacting with us and the Services you are using. Generally, we collect the following categories of personal information:

  • Contact Information, such as name, alias, social media user ID, email address, and similar contact data.
  • Account Information, such as security-related information (including user names and passwords, authentication methods, and roles).
  • User Content, such as content of communications, suggestions, questions, comments, feedback, and other information you send to us, that you provide to us when you contact us, or that you post on our Services (including information in alerts, folders, notes, and shares of content), and similar data.
  • Device & Browser Information, such as network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
  • Usage Information and Browsing History, such as usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information, API calls, and other logs), content interactions (including searches, views, downloads, prints, shares, streams, and display or playback details), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction information (such as scrolling, clicks, and mouse-overs), and download errors), advertising interactions (including when and how you interact with marketing and advertising materials, click rates, purchases or next steps you may make after seeing an advertisement, and marketing preferences), and similar data.
  • Location Data, such as the location of your device and similar location data.
  • Demographic Information, such as country, preferred language, age and date of birth, gender and similar data.
  • Your Image, such as still pictures, video, voice, and other similar data.
  • Financial Information, such as billing address, billing contact details, and similar data.
  • Social Media and Online Content, such as information in social media and online profiles, online posts, and similar data.

Compete may collect or receive additional non-personally identifiable usage information specifically related to the use of a particular feature or offering on our Services, and responses to the offerings and advertisements presented on our Services. Compete may also collect or receive certain non-personally identifiable technical information.

If you are a potential candidate for employment with Compete, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy.

How We Use Information:
Compete collects information in order to provide and enhance our service offerings and to enable users to enjoy our Services. The information is used to operate Compete’s features, to fulfil your specific requests, to personalise the content provided to you, to communicate with you and to conduct research about your use of our Services, to help offer you other products or services that may interest you, and for loss prevention and anti-fraud purposes.

We may also use your personal information for account and network security purposes, including in order to protect our Services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our Services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

Compete may use your personal information to present you with offers on behalf of advertisers and business partners. However, while our business partners and advertisers may receive aggregated data about our users, any personal information of yours will not be shared with third parties, unless you have consented to the sharing of this information. Please note that, notwithstanding the foregoing, your personal information may be disclosed if requested by applicable regulatory authority and/or court with applicable jurisdiction, as determined in good faith by Compete.

Compete may transfer personal information in the event of a transfer of ownership of Compete or any of its Services or products, in which event, your personal information could become subject to a different privacy policy.

From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Apple’s products, services, and customer communications.

If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.

If you apply for a position at Compete or we receive your information in connection with a potential role at Compete, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how Compete handles candidate personal information at the time of application.

Browser Use:
In the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Compete has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would like to keep confidential.

Marketing Choices:
We deliver advertising and marketing across various platforms, such as on our Services or via email, telephone, text messaging, direct mail, and various online channels. Our Services and marketing materials may also include third party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services. You can control cookies and tracking tools.

Links:
Our Services may contain links to other third-party websites or applications (“Third-Party Sites”). Compete does not endorse or authorise any Third-Party Sites that may be linked via our Services, nor does such linking represent any affiliation with that third-party or the Third-Party Site(s). By clicking on a link to a Third-Party Site, including on an advertisement, you will leave our Services and will got to the site or application to which such link directs you.

Third-Party Sites and other sites and applications follow different rules regarding the use or disclosure of the personal information you submit to them. Compete does not control the activities of third parties and does not accept responsibility for any use of your personal information by such third parties and it cannot guarantee that they will adhere to the same privacy and security practices as Compete. You are therefore encouraged to read the privacy policies or statements of the websites and applications you visit/use, before providing any personal information.

Social Platforms:
Unless explicitly requested otherwise, Compete may, at its sole discretion, display any photos and other content, uploaded, displayed or created on our Services, on any social platform such as Facebook, Twitter, Google+, Pinterest, LinkedIn and the like.

Security:
Taking into account the nature, scope, context and purpose of processing personal information, as well as the risks to individuals of varying likelihood and severity, Compete has implemented technical and organisational measures designed to protect and secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. Please note that no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable measures designed to protect personal information, we cannot guarantee that unauthorised third parties will never be able to overcome those measures or use your personal information for improper purposes. Email and messaging systems are not considered secure, so we discourage you from sending us personally information through these media.

Children and Parents:
Our Services are intended for individuals over thirteen (13) years of age. Compete does not target children and does not knowingly collect personal information from children under the age of thirteen (13). Compete only process information about children with the consent of the parents or legal guardians when the information is provided to us by the parents or legal guardian. When a user discloses personal information on our Services, that user is representing to us that he or she is at least thirteen (13) years of age.

If you are under thirteen (13) years of age, then please do not use or access our Services at any time or in any manner. If we learn that personal information of persons under thirteen (13) years of age has been collected on our Services without verified parental consent, we will take the appropriate steps to delete such information.

Modification and Deletion:
In order to delete, modify or update personal information you submitted, please contact us at privacyteam@competeapp.net. The deletion of any of your personal information from our database will not prevent Compete from using anonymous information gathered.

If you require any kind of help, please contact us at privacyteam@competeapp.net.

Retention of Information:
Compete retains personal information in accordance with our records retention schedule, which varies by service, business function, record classes, and record types. We reserve the right to retain personal information for the periods that the personal information is needed to: (a) fulfil the purposes described in this Privacy Statement, (b) meet the timelines determined or recommended by regulators, professional bodies, or associations, (c) comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), and (d) comply with your requests.

Non-UK Users:
Our Services are hosted in the United Kingdom. If you are accessing our Services from a jurisdiction with privacy laws or regulations that differ from United Kingdom laws, please be advised that through your continued use of our Services, you may be transferring your personal information to the United Kingdom and you consent to that transfer. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by applicable data protection laws.

Changes to this Privacy Statement:
We reserve the right to amend this Privacy Statement at any time, for any reason, and without notice to you other than the posting of the updated Privacy Statement on our Services. We may e-mail periodic reminders of our notices and terms and conditions, but you should check this Privacy Statement frequently to see the current Privacy Statement that is in effect and any changes that may have been made to it.

Cookies:
Compete, our Services, websites, interactive applications, email messages and advertisements may use "cookies" to collect information. A cookie is a small data file that is placed in the browser of your computer or on your mobile device for record-keeping purposes. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of our Services, tailoring recommendations to interests and making our Services easier to use. Third party advertisers on our Services may also place or read cookies on your browser.

Next to cookies, other tracking technologies are used which are similar to cookies. These can include web beacons (also known as pixel tags, web bugs or gifs), tracking URLs or software development kits (SDKs). A web beacon is a tiny graphic image of just one pixel that can be delivered to your computer as part of a web page request, in an app, in an advertisement or in an HTML email message. Pixels can be used to retrieve information from your device, such as your device type or operating system, IP address, and time of visit. They are also used to serve and read cookies in your browser. Tracking URLs are used to understand from which referring website the Compete websites or apps are used. SDKs are small pieces of code included in apps, which function like cookies and web beacons.

All these technologies are together referred to in this section as “cookies”.

Cookies are used for different purposes. They allow you to be recognised as the same user across the pages of a website, between websites or when you use an app. The types of information that we collect through cookies include IP address; device ID; viewed pages; browser type; browsing information; operating system; internet service provider; timestamp; whether you have responded to an advertisement; the referring URL; and features used or activities engaged in within the website/apps.

We use cookies for different purposes. The below bullet points outline the types of cookies we use on our Services and why we use them:

  • Technical cookies: These cookies are essential for our Services to perform their basic functions, to make them function correctly. These include cookies that are required to allow registered users to create their account, authenticate and perform account related functions, as well as to save the contents of virtual “carts” for e-commerce functionality.
  • Analytics and Performance cookies: We use these cookies to gain insight into how users interact with our Services. We use these details to improve how our Services function, understand how users interact with our Services, understand the effectiveness of advertisements and communications, and ensure we continue to be interesting and relevant.
  • Functional cookies: These cookies are used to store and remember users’ preferences and to help users to use our Services efficiently and effectively.
  • Security cookies: We use these cookies to help identify and prevent potential security risks.
  • Advertising cookies: These cookies are used to display relevant advertising to users who use our Services, as well as to understand and report on the efficacy of ads served on our Services. They are also used to build user profiles, including showing you ads based on products or services you have viewed or acts you have taken on our (and other) websites and services. These are set by us and trusted third party networks, and are generally persistent in nature.
  • Third Party / Embedded Content: Our Services hosted by us make use of different third-party applications and services to enhance the experience of Services visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons). As a result, cookies may be set by these third parties, and used by them to track users’ online activity. We have no direct control over the information that is collected by these cookies.

Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please note that some functionality of our Services may be impaired if you decline to accept cookies. Visit allaboutcookies.org and the help section of your browser, to learn more about cookies and how to manage or delete them. In the settings for browsers such as Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on which browser you use. Use the "Help" function in your browser to locate the settings you need.

If you have any questions about this Cookie Statement, please contact us at privacyteam@competeapp.net. This cookie statement may also be amended from time to time, therefore check our Services frequently to see the current cookie statement.

Privacy Statement for California consumers under CCPA

This Privacy Statement for California Consumers under CCPA (“California Statement”) is included in our Privacy Statement and explains rights that California consumers may have under the California Consumer Privacy Act of 2018 (“CCPA”).

Any capitalised terms or other terms not defined herein shall have the meaning ascribed to them in the Privacy Statement or, if not defined herein or in the Privacy Statement, the CCPA. To the extent of any conflict between this California Statement and the Privacy Statement, this California Statement shall control only with respect to Consumers and their personal information. If you are located elsewhere, please review our Privacy Statement.

When we use the term “personal information” in this California Statement, we are using that term as CCPA defines it, which CCPA generally defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA). The definition of “personal information” also does not apply to the collection of personal information from job applicants, employees – whether you are our employee or any employee of the entity arranging access to our Services for you, business owners, directors, officers, medical staff, or contractors.

Personal Information We May Collect:
Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information. For all categories of personal information collected, we disclose data to our service providers and other third parties to help us accomplish the business purposes described below, as described in more detail in our Privacy Statement.

For the table below, the list of examples for each category is intended to be illustrative and not exhaustive.

Categories of Personal Information Sources of Personal Information Business and Commercial Purposes
Identifiers (e.g., name, address, e-mail address, account name(s))
  • Websites or services (information collected directly from user)
  • Third-party advertisers/promoters
  • Industry Affiliates
  • Vendors
  • Account activation and administration
  • Customer support and feedback
  • Process, fulfilment, and maintenance of order/installation
  • Delivery of marketing communications
  • Analytics
Commercial Information (e.g., products or services purchased, obtained, or inquired about)
  • Websites or services (information collected directly from user)
  • Third-party advertisers/promoters
  • Industry Affiliates
  • Vendors
  • Customer support and feedback
  • Process, fulfilment, and maintenance of order/installation
  • Delivery of marketing communications
  • Analytics
Internet or Network Activity (e.g., IP address, browser and operating system, referral URL, pages viewed, date/time of visit)
  • Websites or services (information collected directly from user)
  • Third-party advertisers/promoters
  • Vendors
  • Delivery of marketing communications
  • Analytics
Geolocation (physical location of device)
  • Websites or services (information collected directly from user)
  • Third-party advertisers/promoters
  • Vendors
  • Customer support and feedback
  • Process, fulfilment, and maintenance of order/installation
  • Delivery of marketing communications
  • Analytics
Inferences drawn from any of these personal information categories (e.g., interest in services, such as based on feedback and customer support)
  • Websites or services (information collected directly from user)
  • Third-party advertisers/promoters
  • Vendors
  • Customer support and feedback
  • Process, fulfilment, and maintenance of order/installation
  • Delivery of marketing communications
  • Analytics
Financial Information (e.g., credit card information, bank account information)
  • Websites or services (information collected directly from user)
  • Vendors
  • Account activation and administration
  • Process, fulfilment, and maintenance of order/installation

Your CCPA Rights:
If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you may request access to the personal information we collect, use, and disclose about you upon appropriate verification.

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations

Exercising Your Rights:
To exercise the access and deletion rights described above, please submit a request to us by either emailing us at privacyteam@competeapp.net.

Only you, or a person that you authorise to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfil such request. We will require you to provide enough information for us to reasonably verify your identity or a person authorised to act on your behalf. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Do Not Track:
We currently do not respond to any Do Not Track signals or other signals.

Contacting Us:
If you have any question regarding this California Statement or our privacy practices as it relates to this California Statement, please contact us via email at privacyteam@competeapp.net.

Compete will not discriminate against you because you have exercised any of your privacy rights under the CCPA.