Privacy Policy

Introduction

The information in this Privacy Policy describes how we, MagicOrange Group Limited (Company number: 12805411), use the personal data you provide us when you make an enquiry about using, or register to use, the MagicOrange App or use our website https://magicorange.com/ or any other sites of ours (“Sites”) and through any communications with us (“Communications”).

We respect your privacy and protecting your information is paramount.  We want you to be informed and empowered with respect to your privacy when you make an enquiry about using, or register to use, our MagicOrange App or use our Sites and during any Communications with us, so please read this Privacy Policy carefully.  This Privacy Policy sets out our practices regarding your personal data, how we collect, process and treat it, and the rights you have in relation to the protection of your personal data.

Important information and who we are

MagicOrange Group Limited is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: MagicOrange Group Limited
  • Title of data privacy manager: Chief Operating Officer
  • Email address: info@magicorange.com
  • Postal address: Warnford Court, 29 Throgmorton Street, London, EC2N 2AT

Complaints

If you have a complaint relating to the processing of your personal data, please use the contact details above to contact us.

We would appreciate the opportunity to address any concerns or complaints you may have with respect to the MagicOrange App, our Sites, Communications and our data processing practices.  However, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (https://ico.org.uk/make-a-complaint/).

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.  If you need to update the personal data we hold about you, please use the contact details above to contact us.

The data we collect about you

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

  • Communications Data: Details regarding the communications made between us.
  • Identity Data: First name, last name, job title.
  • Contact Data: Email address.
  • Device Data: Includes the type of device you use, your operating system, the type of browser you use, time zone setting.
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.
  • Location Data: Google Analytics to track your location.

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 MagicOrange App 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 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, and Marketing and Communications Data) you consent to giving us about you by filling in forms on our Sites, or through Communications with us (for example, by email or chat). It includes information you provide when you enquire about using, or register to use, the MagicOrange App, download or register the MagicOrange App, subscribe to any of our Services, search for the MagicOrange App or Services and when you report a problem with the MagicOrange App, our Services, or any of our Sites. 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 our Sites or use the MagicOrange App we will automatically collect personal data including device, location, and usage Data. We collect this data using cookies and other similar technologies. Please refer to our Cookie Policy below for further information about how we use cookies and other similar technologies.

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

MagicOrange uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website
  • Remarketing our products/services to you

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

  • Functionality — MagicOrange uses these cookies so that we recognise you on our website and remember your previously selected These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
  • Advertising — MagicOrange uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP MagicOrange sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

How we 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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. When we rely on our legitimate interests, you have the right to object at any time.  For example, we may process your personal data to:
    • Keep our records up to date.
    • Provide you with our services, including for the purpose of quality control and analysis.
    • Develop and improve our services.
    • Communicate and manage our relationship with you.

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.

Purposes for which we will use your personal data

Purpose/activity

 Type of data

Lawful basis for processing

To install the MagicOrange App, to respond to enquiries regarding the MagicOrange App, and register you as a new MagicOrange App user

Identity

Contact

Device

Your consent

To manage our relationship with you including notifying you of changes to the MagicOrange App or any of our services and managing any requests or complaints received from you

Identity

Contact

Marketing and Communications

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services)

To administer and protect our business and the MagicOrange App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To monitor trends so we can improve the MagicOrange App

Identity

Contact

Device

Usage

Marketing and Communications

Location

Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

We will only use your personal data for the purposes for which we collected it (as set out in the table above), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please use the contact details above to contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Disclosures of your personal data

We may need to disclose your personal data to others to facilitate the provision of our services and Sites to you.  Disclosure of your personal information to a third party will only be made where they agree to keep your information confidential and will only be used for the specific purpose for which we provide it to them.  Your data may be disclosed to the other persons or entities as described below.

  • Third parties whom you opt-in to receive direct marketing communications from.
  • Third parties who supply services to us, such as our IT and hosting providers and our payment service provider.
  • Our professional advisors, such as our legal advisors where they require information in order to provide advice to us in relation to the MagicOrange App, our Services, Sites or Communications.
  • Any regulatory authority we may be subject to for the purpose of demonstrating compliance with applicable laws and regulations.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Such third parties as we reasonably consider necessary in order to prevent crime, e.g., the police.

International transfers

Your personal data may be stored and processed outside the UK in countries that may have different data protection rules than our own.  Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that:

  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO; or
  • where we transfer your personal data to third parties restricted countries which are not deemed to provide an adequate level of protection by the ICO, we will use specific contracts approved by the ICO with those third parties which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will only keep your personal data for as long as necessary to carry out the relevant purposes set out in this Privacy Policy and in order to comply with our legal and regulatory obligations, following which we will securely destroy your personal information.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We will provide you with more detail regarding the storage periods for the different types of personal data as and when you request.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

Your legal rights

We are committed to delivering the rights that data protection law provides. Please be aware that these rights are often not absolute, and exemptions may apply.

You have the right to:

  • Be informed and to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy.
  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request 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.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful, but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. 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 will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You can exercise any of these rights at any time by contacting us using the contact details set out at the top of this Privacy Policy.

How we Protect Your Information

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted; 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, loss or damage.

Changes

We keep our privacy policy under regular review.  This version was last updated on 16 February 2024.

We may make changes to this Privacy Policy in future to reflect changes in the way that we process your personal information. Any changes we may make to our MagicOrange Privacy Policy will be posted here and, where the changes are material or we decide it is appropriate, notified to you in any manner we deem appropriate. Please check back frequently to see any updates or changes.