Privacy Policy

This notice applies when you:

• Download and use our Facebook application (Stable Comms), or any other application of ours that links to this Privacy Notice.
• Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SummaryKey points

This summary provides key points from our Privacy Notice, but you can find more details about any of these topics in the table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

ContentsWhat this notice covers

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on?
4. When and with whom do we share your information?
5. How long do we keep your information?
6. How do we keep your information safe?
7. Do we collect information from minors?
8. What are your privacy rights?
9. Controls for do-not-track features
10. Do United States residents have specific rights?
11. Do we make updates to this notice?
12. How can you contact us about this notice?
13. How can you review, update, or delete your data?

01What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• contact preferences

Sensitive information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information from our Facebook application(s)

We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

02How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

03What legal bases do we rely on?

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• For investigations and fraud detection and prevention.
• For business transactions provided certain conditions are met.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• For identifying injured, ill, or deceased persons and communicating with next of kin.
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
• If it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the information is publicly available and is specified by the regulations.
• We may also disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.

04When and with whom do we share your information?

We may need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

05How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

06How do we keep your information safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

07Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

08What are your privacy rights?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information.

We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the contact details below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at [email protected].

09Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

10Do United States residents have specific privacy rights?

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participation in customer surveys or contests, and facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain Category A and Category B information for as long as the user has an account with us.

How we use and share personal information

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data.
• Right to access your personal data.
• Right to correct inaccuracies in your personal data.
• Right to request the deletion of your personal data.
• Right to obtain a copy of the personal data you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

How to exercise your rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at [email protected], or by referring to the contact details at the bottom of this document. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

11Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

13How can you review, update, or delete your data?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.