Privacy Policy

This Privacy Policy sets out how we, All Points North Publications Ltd collect, store and use information about you when you use or interact with our website, www.girltext.com and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st May 2018.

Contents


1. Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

Data controller: All Points North Publications Ltd

How we collect or obtain information about you: When you provide it to us when you join our service.

Information we collect: Your mobile number, date of birth to confirm you're over 18, the first part of your post code ie LS1 and any other optional information you choose to give, including name, a profile about yourself and a photo if you choose to upload one.

How we use your information:

Disclosure of your information to third parties: Only to the extent necessary to operate the services we provide and where required by law or to enforce our legal rights.

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No, we would never sell your information to a third party under any circumstance.

How long we retain your information: For no longer than necessary, taking in to account legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information we collect from you, please see the main section below entitled: How long we retain your information.

How we secure your information: Using appropriate technical and organisational measures such as storing your information on secure servers and only granting access to your information where necessary.

Use of cookies: We do not use cookies or similar technologies on our website.

Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law Where we do so, we will ensure appropriate safeguards are in place.

Use of automated decision making and profiling: We do not use automated decision making or profiling.

Your rights in relation to your information

Sensitive personal information: We collect what is commonly referred to as 'sensitive personal information'. For more information, please see the main section below entitled Sensitive Personal Information.


2. Our details

The data controller in respect of our website is All Points North Publications Ltd, (company registration number: 02524607 of 1 Commercial Court, Briggate, Leeds, LS1 6ER. You can contact the data controller by writing to All Points North Publications Ltd, or sending an email to info@apnuk.com.

If you have any questions about this Privacy Policy, please contact the data controller.


3. Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

We use a third party server to host our website called WebHosting UK, the privacy policy of which is available here: https://www.webhosting.uk.com/privacy-policy/

Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Cookies and similar technologies

We do not use cookies or similar technologies in relation to our website.


4. Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Mobile Phone Number

When you contact us by SMS to join the service advertised on this website we collect your mobile phone number. By texting in to the short code advertised on the site you are providing your consent for us to process this information. We also collect the following information during the sign up process for the service:

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: We provide an SMS chat service, where we use premium rate billing direct to your handset therefore your mobile number is essential for us being able to provide this service.

Transfer and storage of your information

We use a third party email provider to store the text messages submitted by and sent to your handset. Our third party provider is located in Germany.

Phone Call

When you contact us by telephone, we collect your phone number and any information provided to us during your conversation with us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: To provide customer service for our advertised SMS chat service.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: To provide customer service for our advertised SMS chat service.


5. Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We do not receive information about you from third parties.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.


6. Marketing Communications

This section sets out our intentions to market to our existing customers.

Email Marketing: We do not send marketing emails to our customers.

SMS Marketing: we send FREE marketing text messgaes marketing our own services and products.

You can opt-out from receiving marketing text messages at any time by texting XSTOP to 85722.

We will send you marketing text messages in relation to our own similar services and products if you do not opt out from receiving them.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: direct marketing and advertising our products and services.

The Privacy and Electronic Communications Regulations

The Privacy and Electronic Communications Regulations (PECR) sit alongside the Data Protection Act and the GDPR. They give people specific privacy rights in relation to electronic communications.

Section 131 of the PECR Marketing Guidance confirms the following:
Although organisations can generally only send marketing texts or emails with specific conset, there is an exception to this rule for existing customers, known as the 'soft opt-in'. This means organisations can send marketing texts or emails if:

More information please visit the following pages on the ICO's website:


7. Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Disclosure of your information to other third parties

We do not display the identities of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom's legal framework, we have a legitimate interest in complying with these obligations.


8. How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for [insert period for which you retain information from server logs.

Contact information: your contact information will stay on our system for a period of 2 years after the last action on the service after which it will be automatically deleted.

Information submitted to the service: any information submitted by your to the service including your name and a profile will stay on our system for a period of 2 years after the last action on the service after which it will be automatically deleted.

Message logs: your message logs will stay on our system for a period of 2 years after the last action on the service after which it will be automatically deleted.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further months, after which point we will delete your information.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:


9. How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.


10. Transfers of your information outside the European Economic Area

All of your information is stored in the following European Economic Area (EAA) countries: United Kingdom and Germany.

Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organtisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.


11. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to All Points North Publications Ltd, 1 Commercial Court, Briggate, Leeds, LS1 6ER or sending an email to info@apnuk.com:

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner's Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.


12. Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to Data Controller, All Points North Publications Ltd, 1 Commercial Court, Briggate, Leeds, LS1 6ER or sending an email to info@apnuk.com:

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:


13. Sensitive Personal Information

'Sensitive personal information' is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

Sexual Orientation
When you join the service your sexual orientation will be logged and processed to ensure that we deliver profile matches of the appropriate people.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: We provide an SMS chat service, where we will ask you your gender and orientation to be able to pair you with appropriate matches.

If, however, you inadvertently or intentionally transmit other sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive information under Article 9(2)(a) of the General Data Protection Regulation.


14. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.


15. Children's Privacy

Because we care about the safety and privacy of children online, we comply with the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@apnuk.com


16. Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

0