Last Updated: October 6th, 2017
Our Privacy Policy will help you understand what information we collect and process using the Corsham Institute Observatory for a Connected Society Application, hereinafter referred to as “the App”, explain how we use it, and what choices and rights you have in connection with your personal data.
When we refer to “Corsham Institute” within this Privacy Policy, we are referring to Corsham Institute Limited of The Courtyard, Hartham Park, Corsham, Wiltshire SN13 0RP, the “Data Controller” for this App, and responsible for the content and related services or features which may be made available to you from using this App.
Corsham Institute is based within the United Kingdom, and as such is registered with the Information Commissioner’s Office (ICO) as a Data Controller under the UK Data Protection Act of 1998 (registration number ZA265518). We have also aligned our Privacy Policy with the EU General Data Protection Regulation (GDPR) which comes into effect on 25th May 2018, under the supervision of the Information Commissioner’s Office (ICO) within the United Kingdom.
Corsham Institute has completed applicable Data Protection Impact Assessments (also known as Privacy Impact Assessments) for activities related to this App, and these are available upon request from the Corsham Institute’s Data Protection Officer (see Section 11).
You may voluntarily decide to download, register and use our App if you are seeking more information, to be notified of events, or for other related purposes. Your decision to disclose your personal data to us is entirely voluntary, and by doing so, you are providing us with your specific consent to use your personal data only for the purposes for which you have disclosed it to us, and which are summarised within this Privacy Policy. You can vary or withdraw your given consent at any time.
Corsham Institute may access and use the personal data you have provided only for the purposes for which you have submitted it to us to (a) provide information to you, (b) make contact with you, (c) provide services to you, or (d) maintain the functionality, operations and security of the App. We will not use your personal information for any other purposes, for example the communication of marketing material, unless we have received your specific consent for us to do so. We will not share your personal data with any other organisation, other than the declared Data Processors recorded in Section 6.
We will at all times handle and store your personal data in accordance with industry best practice aligned with ISO27001, the international standard for information security. This includes the activities and procedures undertaken by our own personnel and those of our authorised third parties (see Section 6), and technical controls have been implemented to prevent unauthorised access, compromise or theft of information from the App, supporting computer systems and related premises.
GDPR specifies a set of personal data categories which are considered to be “sensitive”, and which require special consideration by Data Controllers. This App, and any services available from it, do not knowingly collect or process any sensitive personal data, and supporting Data Protection Impact Assessments supporting this position are available upon request from the Corsham Institute’s Data Protection Officer (see Section 11).
This App, and any services available from it, are not directed to children under the age of 13. If you learn that a child under the age of 13 has provided us with their personal information without having parental consent, please contact the Corsham Institute Data Protection Officer (see Section 11) immediately so that we can take appropriate action.
As prescribed within the EU General Data Protection Regulation, you have several rights connected to the provision of your personal data to Corsham Institute using the App. These include your rights to formally request that Corsham Institute:
To contact Corsham Institute, please see Section 11 below.
If Corsham Institute does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office (ICO) to make a compliant. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.
You have the right to be promptly informed by Corsham Institute of any personal data loss, theft or compromise arising directly or indirectly from the App, and any supporting systems or declared Data Processors (see Section 6) involved with delivering, supporting, maintaining, monitoring or improving the App. Similarly, Corsham Institute is required to notify the Information Commissioner’s Office (ICO) promptly, as the supervisory authority for the United Kingdom.
As a user of the App, you have a responsibility to safeguard and manage your App login credentials securely. This requires you to ensure that they are changed frequently, of sufficient strength and complexity, different from any other passwords you may use, and not recorded in a format which could be accessed or guessed by others. If you suspect that your credentials have been compromised, you should notify Corsham Institute immediately. We will not be liable for any personal data loss, theft or compromise where this can be attributed to your failure to secure your App login credentials.
To make an informed decision on whether to provide your personal data to Corsham Institute using this App, we need to make you aware of the organisations that act as Data Processors for us in the provision of the App and its functionality to you:
Disciple Media Limited, with its registered address at Labs Atrium, Stables Market, Chalk Farm Road, London NW1 8AH, is registered with the Information Commissioner's Office (ICO) within the UK under the UK Data Protection Act 1998 (registration number ZA147341). The purposes for which Disciple Media Limited are engaged is to process and store personal data on behalf of Corsham Institute in order to deliver the App to you, and such processing and storage takes place only within the UK.
The activities within which each of these named Data Processors participates have been recorded within the applicable Corsham Institute Data Protection Impact Assessments, and these are available upon request from the Corsham Institute’s Data Protection Officer (see Section 11).
Neither Corsham Institute nor any of the other Data Processors identified in Section 6 of this Privacy Policy transfer or store any user personal data from the App beyond the European Economic Area (EEA).
When using this App, you should be aware that certain information may be stored locally on your device using cookies or within the App’s local storage. We may use both session-based and persistent cookies, dependent upon how you choose to use or interact with the App.
Cookies are small text files sent by us to your computer, or from your computer or mobile device to us each time you access or use the App, and are necessary for the App to function. They are unique to you or your web browser, and may contain personally identifiable information as well as technical information (e.g. your device manufacturer and model, screen resolution, internet service provider, browser, and geo-location data). Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them, or until they expire.
We use cookies which are not specific to your account but are unique and allow us to undertake analytics and customisation activities, among other similar things. If you decide to disable some or all cookies, you may not be able to use some of the functions of our App. We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies from their website.
The App includes relevant hyperlinks to external websites which are not directly controlled by Corsham Institute. Whilst all reasonable care has been exercised in selecting and providing such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the ongoing suitability of external links, nor do we continually verify the safety or security of the contents which may be provided to you. You are advised, therefore, that your use of external links is at your own risk and we cannot be responsible for any damages or consequences caused by your use of them.
We may change this Corsham Institute Observatory for a Connected Society Application Privacy Policy from time to time, and if we do we will highlight any changes within the App. If you continue to access or use the App after notified changes have come into effect, you will have agreed to the revised policy.
If you have any questions about this Privacy Policy, would like to exercise any of your statutory rights (including viewing Data Protection Impact Assessments) or to make a complaint, please write to:
The Data Protection Officer
Corsham Institute Limited
The Courtyard, Hartham Park
Corsham, Wiltshire, SN13 0RP
Effective Date: October 6th, 2017
The App is a mobile platform for users ("you", and "your") that enables you to access content alongside social and interactive features in connection with The Observatory for a Connected Society. The App has been produced for the Corsham Institute (Ci) by Disciple Media Limited ("we", "us" and "our"), company number 08075740, whose place of business is at Disciple Media, Interchange Atrium, Stables Market, Chalk Farm Road, London, NW1 8AH, United Kingdom. If you have any questions about these terms and conditions or the Observatory app, then please email ocs@corshaminstitute.org.
These Terms and Conditions ("Terms") and the Privacy Policy above apply to your use of the App.
By downloading and using the App, you accept these Terms. This will create a binding legal contract between you and us. If you do not agree to the Terms, we kindly ask that you do not download or use the App. Unless otherwise specified in the App details on the applicable App Store, to use the App you must be 18 or older (or be 13 or older and have your parent or guardian's consent).
We license use of the App to you on the basis of these Terms and subject to any rules or policies applied by any App store provider or operator from whose platform you download the App (“App Store”). We do not sell the App to you. We remain owners of the App at all times.
We may occasionally make changes to the App, these Terms, or our Privacy Policy. If we do, we'll notify you either by updating the Effective Date listed above or via the App or other contact details you have provided. Your continued use of the App expresses your acceptance of the changes. You must stop using the App if you disagree with any changes to the App, these Terms, or our Privacy Policy.
From time to time we may issue updates to the App via the App Store. Depending on the update, you may not be able to use the App until you have downloaded the latest version of the App and accepted any new terms.
You may access the App by downloading and installing the App to your device from the App Store. Although we are working to ensure that the App is compatible across various devices, we cannot guarantee that the App will work with all devices. You should check the minimum requirements and specifications (including memory space and operating system) as set out in the App details on the applicable App Store before downloading the App. To download the App, you will need a valid App account (as applicable to your device), linked to a valid credit or debit card or as otherwise required on the relevant App Store.
It is your responsibility to ensure that you are able to comply with the relevant system requirements as described above. We accept no responsibility for any lack of functionality that is due to your equipment (including your device, internet connection, operating system or settings and software). Access to parts or all of the App and any or all content on the App may be restricted from time to time to allow for repairs, maintenance or updating. We reserve the right to withdraw, take down or amend all or part of the App and all or part of the content on the App (whether uploaded by us, you or other users) at any time.
It is your responsibility to pay for all costs and expenses (including all telephone call or line charges or Internet service data access) that you may incur using the App.
Your use of the App and enjoyment of its features and content hosted or made available through the App may vary in functionality, availability and quality depending on the type of device and operating system and any restrictions imposed by our content providers.
In consideration of you complying with these Terms, we grant you a non-transferable, non-exclusive, revocable licence to use the App on your device(s) and to view the content contained on the App for your personal, non-commercial use, subject to and in accordance with these Terms, the Privacy Policy and the applicable App Store rules, which are incorporated into these Terms by reference.
You agree:
We may terminate these Terms and close your account at any time without notice if we cease to provide the App.
In addition to our right to remove any content from the App, we reserve the right to suspend, restrict or terminate your access to the App at any time without notice if we have reasonable grounds to believe you have breached any of these Terms. We also reserve the right to disable your account at our reasonable discretion. Suspension, restriction or termination of your access to the App will not limit our right to take any other action against you that we consider appropriate.
You may stop using the App at any time, or choose not to renew your subscription if applicable at the end of your current subscription period in accordance with sections 4(a)-(b) above.
You acknowledge that the App, the content provided on the App and all copyrights, patents, trademarks, trade secrets, source code, object code and other intellectual property associated therewith are, and shall remain, the property of us or our licensors. You are not granted any intellectual property rights in or to the App or the content on the App except as expressly set out in these Terms. You are not authorized to use any logos or trade marks or trade names (whether registered or unregistered) in any manner. You may only use the App for personal, non-commercial purposes.
The service and content provided through the App and the App itself are our property or the property of our licensors.
You are strictly only entitled to use the App, and consume content made available through the App, in accordance with these Terms. We may need to notify you of other terms affecting your use of certain licensed content if requested by our licensors from time to time, and will do so by making changes to these Terms.
The App and any other software made available to you via the App is licensed (not sold) to you, meaning that we or our licensors continue to own all copies of the App and other software when it is installed on your device. We may freely assign these Terms or any part of them, but you may not assign your rights under these Terms, or any part of them, nor may you sub-licence your rights under these Terms, to any third party.
These terms do not grant you any rights to use any of our or the Observatory’s intellectual property, such as trade marks, domain names, logos or other branded features, which belong to us and our licensors respectively.
We respect the intellectual property rights of others and expect users of the App to do the same. As part of the functionality of the App we may allow you and third parties to upload, transmit, send or receive content, data, ideas, communications and other materials to the App (“User Generated Content”). By providing any User Generated Content through the App, you grant us and our affiliates and our service providers, and each of their and our respective licensees, successors and assign the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties any such material for any purpose. You represent and warrant that you own or control all rights in and to your User Generated Content and have the right to grant the licence granted above to us and our affiliates and our service providers, and each of their and our respective licensees, successors and assigns. We are under no obligation to, and we do not, review such materials for the purposes of determining copyright infringement. Therefore, your reliance on User Generated Content is at your own risk. Because we have no control over User Generated Content, you acknowledge and agree that we are not responsible for the accuracy or availability of User Generated Content, and we neither endorse nor are responsible or liable for any User Generated Content that appears on the App. We shall have the right (but not the obligation) to delete, remove, monitor, or edit User Generated Content and block links to the App through technological or other means without prior notice. We also reserve the right to terminate access to the App if we believe a user is posting infringing material.
If you live outside of the United States, you are a rights holder and you believe that your copyright is being infringed by any material on the App, please contact us in writing via email at alvin.chan@disciplemedia.com with a copy to FAO: Legal, Disciple Media Limited, Atrium Building, Stables Market, Chalk Farm Road, London NW1 8AH, United Kingdom stating the following:
The Digital Millennium Copyright Act of 1998 (the “DMCA”) provides recourse for copyright owners who believe that material appearing on the internet infringes their rights under U.S. copyright law. If you believe in good faith that materials available on the App infringe your copyright, you (or your agent) may send us a notice requesting that we remove the material or block access to it. If you believe that copyrighted materials have been copied in a way that constitutes copyright infringement, please send an e-mail or written notice to our Designated Agent for notices of infringement and provide the following:
Send the completed notice to our Designated Agent for claims of copyright infringement at: Alvin Chan, Disciple Media Limited, Atrium Building, Stables Market, Chalk Farm Road, London NW1 8AH, alvin.chan@disciplemedia.com
By using the App, you consent to us collecting and using technical information about your device and related information for the purpose of helping us to improve the App and provide any services to you. For more information on how we use your personal data, please see our Privacy Policy section at the top of this document.
The App may make use of location data sent from your device. By using the App, you consent to us and our affiliates’ and licensees’ transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based features of the App. You may withdraw this consent at any time by turning off the location service settings on your device.
Nothing in these Terms excludes or limits liability for death or personal injury caused by negligence or fraud.
We are not responsible for:
For any loss or damage suffered by you or anyone else that may arise from use of the App and which is not otherwise excluded under this section 11, to the extent permitted by law our liability is limited to £100.
We do not endorse or take any responsibility for statements, advertisements or any content whatsoever transmitted through, or linked to from or via, the App by other users or third party service providers. We are not responsible for any transaction you may enter into with a third party via the App and it is up to you to decide whether or not to do so.
The App and the service provided through it is provided without express or implied warranty or condition of any kind, on an "as-is" basis, subject to applicable law. You agree that you must evaluate, and that you bear all risks associated with, the use of the App, including without limitation, any reliance on the accuracy, completeness or usefulness of any materials available through the App.
We have no liability to you for any loss of profit, loss of business, business interruption or loss of business opportunity.
You acknowledge and accept that your access to the App is dependent on connectivity over communications networks and facilities that are outside of our operation and/or control and that your use of the App may be subject to limitations, delays and other problems inherent in the use of such networks and facilities.
We disclaim all warranties with respect to the App including, but not limited to, the warranties of non-infringement and title. We give no warranty that your use of the App will be uninterrupted or error free, that the information obtained from the App will be accurate, complete, current, or reliable, that the quality of the App will be satisfactory to you, or that errors or defects will be corrected. You acknowledge and accept that we are not responsible for any loss or damage of any kind that you may suffer as a result of any interruption or delay to your access to the App, or as a result of any failure or error in the transfer of data over those networks and facilities in connection with your use of the App.
The App may include and link to features, reports, consultations, videos, podcasts, websites and services (including social applications like Twitter, Facebook and LinkedIn) that are provided by a third party. We do not control such third party sites or services and are not responsible for the content of such sites or services. Our inclusion of links does not imply any endorsement or association with their operators. The terms applicable to use of that third party service will apply and we will not be responsible for anything that is done or not done by you or the third party service provider in connection with your use of their service. We recommend that you check the applicable third party service’s terms and conditions of use and sale before using such third party service or purchasing any products or services.
If you need to contact us, please email us at ocs@corshaminstitute.org or write to us at Disciple Media Limited, Atrium Building, Stables Market, Chalk Farm Road, London NW1 8AH. Please note that we are only responsible for the App and do not represent the Observatory for a Connected Society. If we have to contact you, we will do so by e-mail to the address you provide to us when you signed up for the App or via the App.
Unless otherwise required by applicable law, any disputes in connection with these Terms will be governed by and interpreted in accordance with the laws of England and Wales and the courts of England and Wales will have exclusive jurisdiction to hear any claims made in relation to these Terms. If the court in your country will not apply the laws of England and Wales, or if the courts in your country will not permit you to consent to the jurisdiction of the courts in England and Wales, then your local law and jurisdiction will apply to such disputes related to these Terms. You agree that you will not file a class action, or participate in a class action against us.
We can assign, sub-contract and/or otherwise transfer any or all of our rights and/or obligations under these Terms to any company, firm or person. Please note that you may terminate your agreement with us at any time in accordance with sections 4(a)-(b). You may not transfer your rights or obligations under these Terms to anyone else. If our agreement with you is terminated for any reason we shall be entitled to continue to use all rights already granted by you to us (including our rights in relation to any content posted or uploaded by you to the App) and all of our rights and remedies against you for any breach of these Terms arising before the date of termination shall continue in full force.
If you breach these Terms and we take no action against you, or if we delay in doing so, that will not mean that we have waived our rights against you and we will still be entitled to enforce our rights and remedies against you in relation to that breach and to use our rights and remedies in any other situation where you breach these Terms.
If any part of these Terms is disallowed or found to be ineffective by any court or regulator, the remainder of the Terms will continue to govern each of our respective obligations.
These Terms are not intended to give rights to anyone except you and us.
Except as otherwise expressly stated, these Terms contain the entire agreement between us and you relating to use of the App and supersede any previous agreements, arrangements, undertakings or proposals, written or oral, between us and you relating to use of the App.