Privacy Statement - weMove

weMove (“We”, “us”) respects the privacy rights of our users and is committed to protecting the information collected through our online products, services, and websites (any or all of which are referred to as “Services’’). We have adopted this privacy policy (“Privacy Policy’’) to explain how weMove collects, stores, and uses the information collected in connection with our Services.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This policy (together with our “Terms of Use” as set out at https://www.wemovetogether.uk/ and any additional terms of use referred to) applies to the use of all the Services hosted at www.wemovetogether.uk that you can access or use via any digital device (e.g. computer or tablet) (“Devices”) from 18 September 2023 onwards.

By using, registering to or in other way accessing any of our Services, you agree to this privacy policy and give an explicit and informed consent to the storage, use and processing of your personal data in accordance with this privacy policy. If you do not agree to this privacy policy you should not use, register or otherwise access any of our services. Our Services are not intended for children below 16 years old and we do not knowingly collect data relating to children below 16 years old.

We reserve the right to modify this Privacy Policy at any time: please ensure you review it frequently. If we make material or significant changes to this Privacy Policy, the updates will be posted to the website at www.wemovetogether.uk. Any changes to this Privacy Policy will be effective upon their being posted on the weMove website. Your continued use of our Services will signify your acceptance of the changes to this Privacy Policy. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Contact details

Queen Mary University of London; Email address: [email protected], Postal address: Queen Mary University of London, Mile End Road, London, E1 4NS.

1. Who can use “weMove”

We want our Services to be as open and inclusive as possible, but we also want it to be safe, secure and in accordance with the law. So, we need you to commit to a few restrictions in order to use our Services.

• You must be at least 13 years old. If you are aged 16 or under, your parent/guardian is the only person allowed to provide your personal information to our site. Users below 16 cannot use our Services unless their parent or guardian does so and provide us with your personal information.

• You must not be prohibited from receiving any aspect of our Service under applicable laws or engaging in payments-related Services if you are on an applicable denied party listing.

• We must not have previously disabled your account for violation of law or any of our policies.

• You must not be a convicted sex offender.

1. The data we collect or may collect about you and how we use it

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data: this may include, first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, age sex, gender, security password

• Contact Data: billing address, delivery address, email address and telephone numbers

• Financial Data: bank account and payment card details

• Transaction Data: includes details about payments to and from you and details of purchases of our Services.

• Device Data: includes the type of device you use, a unique device identifier (for example, IP address, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting

• Content Data: includes information that you upload or enter, including list of people/ registered users that you share information with, connection with other registered users, login information, photos, audio recordings and their transcriptions, videos, written feedback or other digital content.

• Profile Data: includes your username and password, purchase history of our Services, your interests, preferences, sports/arts schools/institutions attended, country/region/town of practice, type of dance/music used, feedback and survey responses, connection to other users.

• Usage Data: includes details of your use of any of our Services or your visits to any of Our Sites including, but not limited to, time, frequency, duration of usage, IP address, sessions you viewed or searched for; page response times, information about feedbacks given by experts, comments entered, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any email or phone number used to contact us, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

• 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

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.

How we use or may use your personal data

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

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered 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.

Consult the glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We may collect and process the following information for the following purposes:

Purposes for which we will use or may use your personal data

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on our website and the Services Sites (together “Our Sites”), or by corresponding with us (for example, by email, phone or chat). It includes information you provide when you register to use our Services, subscribe to any of our Services, search for Service, share data via functions of our Services, enter a competition, promotion or survey, or add comments and annotations and when you report a problem with our Services or any of Our Sites. This may include signing up for our newsletter. If you register for any services on https://app.wemovetogether.uk/ we may ask for further personal details from you, for instance, the time, frequency and duration of your activities on weMove, audio recordings, type of dance performed. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Services we will or may automatically collect personal data including Device, Content and Usage Data.

Information you give to us. You may give weMove information about yourself by filling in forms on our site or by corresponding with us via phone, email or otherwise. This may include signing up for our newsletter. If you register for any services on https://app.wemovetogether.uk/ we may ask for further personal details from you, for instance, the time, frequency and duration of your activities on weMove, audio recordings, type of dance performed. In such instances we will not use your data without your consent.

We will use this information to provide you with newsletters, information about weMove and its website and asking for user’s feedback and comments.

From time to time, we may provide your information to our weMove team and the research team for research and analysis purposes so that we can monitor and improve the services we provide. We as weMove team may contact you by e-mail to ask you for your feedback and comments.

Information we collect. With regards to the visits to our website we may collect information such as: information about your visit, number of logins, sessions you viewed or searched for; page response times, number of page response visits, information about feedbacks given by experts, comments entered, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call us.

We may use aggregate information and statistics for the purposes of monitoring website usage in order to help us develop the website and our services and may provide such aggregate information to weMove team. These statistics will not include information that can be used to identify any individual.

If you no longer wish to receive the information above, please send an e-mail message with the word ‘Unsubscribe’ in the heading and your name.

Use your information in accordance with data protection laws

Personal data is kept as long as individual is registered or otherwise removed and deleted after receiving a request to [email protected]. Data protection laws require that we meet certain conditions before we are allowed to use your data in the manner described in this privacy policy. We take our responsibilities under data protection laws extremely seriously, including meeting these conditions. To use your personal data, we will rely on the following conditions, depending on the activities we are carrying out:

• Consent. We may provide you with certain usage or promotion information by email about our services or products or those of third parties where you have not unsubscribed and where you have signed up for the newsletter. Please note that we will use your personal information to provide certain usage or promotion information for the same or similar services you have previously used.

• Compliance with legal obligations. As an entity incorporated under the laws of England and Wales, weMove is obliged to comply with UK laws and guidance provided by UK regulatory bodies. In particular, we may need to process your personal information to verify your identity, and to establish whether you have been barred from using our site due to objectionable behaviour. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.

2. Our use of cookies and other information gathering technologies

Cookies are small pieces of information stored by your browser on your computer’s hard drive so that the website you have visited can remember who you are. We use cookies (and/or other tracking technologies) to distinguish you from other users and to remember your preferences. This helps us to provide you with a good experience when you use our Services or browse any of Our Sites and also allows us to improve the App and Our Sites.

We use temporary session cookies to store the user's identifier, email, name and profile picture, and session access token while the user is signed in. The cookies are deleted once the user closes the session (sign out).

3. How we protect your information

The internet is not a secure medium. However, we have put in place various security procedures as set out in this policy. We operate and protect our systems with the use of, but not limited to, firewalls, limited access to information, use of passwords and encryption and such other technologies that may assist weMove the security, protection and keep private the information we hold. We also keep your information confidential. The internal procedures of weMove cover the storage, access and disclosure of your information.

4. How long we keep your information for

Personal data is kept as long as individual is registered or otherwise removed and deleted after receiving a request. The data will be stored for the maximum duration of 5 years, although some of your data will be deleted in shorter timescales, where possible.

Disclosure of your information

weMove may share your personal information with our team and research members of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries). We will only share your personal information with other members of the group for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes. We will only disclose your information:

• in the event that we consider selling or buying any business or assets or merge or enter into a joint venture with another business entity in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;

• in the event of any insolvency situation (e.g. the administration or liquidation) of weMove or any of its group;

• if we, or substantially all of our assets, are acquired by weMove, in which case personal data held by us about our users will be one of the transferred assets;

• in order to enforce or apply our website terms and conditions;

• to protect the rights, property, or safety of us, our staff, our customers/users, or others. This includes exchanging information with other companies and organisations (including without limitation, your employer, educational institution, email or internet provider, your parents (if you are under the age of 16) and/or the metropolitan police or other law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.

5. Updating your details

If any of the information that you have provided to weMove changes, for example if you change your e-mail address and name or if you wish to cancel your registration, please let us know the correct details by sending an e-mail to [email protected]

6. Transfer outside the UK

Owing to the global nature of the internet infrastructure and the associated security issues, the information you provide may be transferred in transit to countries outside the United Kingdom that do not have similar protections in place regarding your data and its use as set out in this policy. However, please note that we have taken the steps to try to improve the security of your information and we will do our best to protect your personal data, although we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Currently weMove secure servers are located within the UK, should we propose to move the servers to outside the UK we will take all steps reasonably necessary to ensure adequate protections are in place and that your data is treated securely and in accordance with this privacy policy.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

7. Your Rights

You have a number of rights under data protection law in relation to the way weMove process your personal data, although these are not absolute and, in some instances, weMove may be unable to accept your request, in which case we will respond to you to explain why. Your rights are set out below. You may contact weMove by sending an e-mail to [email protected] to exercise any of these rights, and weMove will respond to any request received from you within one month from the date of the request. Please address any questions, comments and requests regarding our data processing practices to weMove team in this way in the first instance.

You have the right to:

• A right to access personal data held by “weMove” about you.

• A right to require us to rectify any inaccurate personal data held by us about you.

• A right to request an erasure of your personal data. This enables you to ask us to delete or remove personal 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.

• A right to withdraw consent at any time where we are relying on consent to process your personal data by deleting your account. 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.)

• you also have the right to make a complaint to the Information Commissioner's Office. Their address is [email protected]. For escalating procedures, our Data Protection Officer may be contacted using the following details: Queen Mary University of London, Mile End, G.E Fogg Building, London E1 4NS, E: [email protected] ,T: +44 (0) 20 78828 798

Glossary

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

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.

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

Third parties

Internal third parties are members of staff at Queen Mary University of London acting as joint controllers or processors and who are based in UK and provide IT and system administration services and undertake leadership reporting.

External third parties are service providers acting as processors based in UK who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK who provide consultancy, IT consultancy, web development, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

This policy was last reviewed and updated: 18 September 2023