As of June 2021
Table of contents
The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:
Vollou Ltd
103c Camley St, London N1C 4PF
United Kingdom
contact@vollou.com
https://vollou.com
The designated data protection officer is:
DataCo International UK Limited C/O
One Peak Limited 2nd Floor 41 Great Pulteney Street
London W1F 9NZ
+442035146557
Email: privacy@dataguard.co.uk
https://www.dataguard.co.uk/
In general, we only process the personal data of our users to the extent necessary in order to provide a functioning app with our content and services. The processing of personal data regularly only takes place with the consent of the user. Exceptions include cases where prior consent technically cannot be obtained and where the processing of the data is permitted by law.
Art. 6 (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data. As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.
When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (c) UK GDPR serves as the legal basis.
If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) UK GDPR serves as the legal basis.
If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) UK GDPR UK GDPR will serve as the legal basis for the processing of data. If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) UK GDPR UK GDPR will serve as the legal basis for the processing of data.
The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if it was provided for by international regulations, laws, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.
When your personal data is processed, you are subsequently a data subject in the sense of the UK GDPR and have the following rights:
You may request from the data controller to confirm whether your personal data is processed by them. If such processing is the case, you can request the following information from the data controller:
The purpose for which the personal data is processed;
The categories of personal data being processed;
The recipients or categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed;
The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;
The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the data controller or a right to object to such processing;
The existence of a right of appeal to a supervisory authority;
All available information on the source of the data if the personal data is not collected from the data subject;
The existence of automated decision-making including profiling under Article 22 (1) and (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.
You have the right to request information on whether your personal data will be transmitted to a third country or an international organisation. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.
You have a right to rectification and/or modification of the data controller, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay
You may request the restriction of the processing of your personal data under the following conditions:
If you challenge the correctness of your personal data for a period of time that enables the data controller to verify the accuracy of your personal data;
The processing is unlawful, and you refuse the erasure of the personal data and instead demand the restriction of the use of the personal data;
The representative no longer needs the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate reasons of the data controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest.
If the processing has been restricted according to the beforementioned conditions, you will be informed by the data controller before the restriction is lifted.
If you request from the data controller to delete your personal data with immediate effect, they are required to do so immediately given that one of the following applies:
Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent, to which the processing is allowed pursuant to Art. 6 (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR and there is no other legal basis for processing the data
According to Art. 21 (1) UK GDPR you object to the processing of the data given that the processing of the data is justified by a legitimate interest, or you object pursuant to Art. 21 (2) UK GDPR.
Your personal data has been processed unlawfully.
The act of deleting your personal data will invoke a legal obligation under the applicable law to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.
If the data controller has made your personal data public and has to delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.
The right to deletion does not exist if the processing is necessary
to exercise the right to freedom of speech and information.
to fulfil a legal obligation required by the applicable law to which the representative is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative;
for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) UK GDPR;
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or to enforce, exercise or defend legal claims.
If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.
You reserve the right to be informed about the recipients of your data by the data controller.
You have the right to receive your personal data given to the data controller in a structured, standard and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, given that
the processing is based on a consent in accordance with Art. 6 (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or on a contract in accordance with Art. 6 (1) (b) UK GDPR and the processing is done by automated means.
In exercising this right, you also have the right to maintain that your personal data relating to you are transmitted directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.
Subject to your situation, you have, at any time, the right to object against the processing of your personal data pursuant to Art. 6 (1) (e) or (f) UK GDPR; this also applies to profiling based on these provisions.
The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling insofar as it is associated with direct marketing. If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
You have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.
You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.
You have the right to not be subjected to a decision based solely on automated processing – including profiling – that will have a legal effect or affect you in a similar manner. This does not apply if the decision:
is required for the conclusion or execution of a contract between you and the data controller,
is permitted by the applicable law to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or is based on your explicit consent.
However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or g UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or their representative, to express your opinion on the matter, and to contest the decision.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to the relevant supervisory authority if you believe that the processing of the personal data concerning you violates the UK GDPR. In the UK, the relevant supervisory authority is the Information Commissioner's Office (ICO):
Information Commissioner's Office (ICO) Wycliffe House
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113
https://ico.org.uk/global/contact-us/
The ICO shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.
On this page, we inform you about the data protection provisions applicable in the Vollou App for Android and iOS ("App"). The App is an offer of Vollou Ltd, 61 Eccleston Square Mews, SW1V 1QN, United Kingdom ("Vollou", "we" or "us").
Vollou has created a platform that will not only allow users to save and share their best memories of the night with their friends, but will also work to recommend the users on new places to go out (given their current partying habits) as well as offer the bars and clubs a better understanding as to who is attending their parties, and how to market to grow their current customer base.
Functions of the app:
The app will have the following functions:
A music recognition software to identity and save all of the songs playing throughout the night
An in-app camera and shared folder which allows users to take pictures through the app (or upload after) and save everyone’s pictures in one location
Ability to use data on user’s partying habits to recommend parties, events and locations to check out
Ability to provide user data to clubs for a better understanding on their events and their customer base
Use data to help clubs better market their events to the correct demographic
Data processed (currently and in the future):
Name
Email address
Age
Gender
Music taste on Vollou
Your posts including the photos and videos you upload through the app
Information about your activity through our app and services
Photos from your camera roll when you grant us access to your camera or photos.
Location Information when using our app
Spending of the user at the club
Children
Our services are not intended for—and we don’t direct them to—anyone under 13. And that’s why we do not knowingly collect personal information from anyone under 13. Furthermore, we may limit how we process some of the information of users between 13 and 16. In some cases, this means we will be unable to provide certain functionality to these users.
Third parties do not get access to server log files.
We process this data mainly:
To enable the use of the app
To identify you as a user or authorised user of the app when you log in to the app
The legal basis for the processing of personal data in the context of the creation and use of a user account is the consent of the user pursuant to Art. 6 (1) (a) UK GDPR.
The processing of technical data serves to protect a legitimate interest of our company to provide a functional application for users and is therefore based on Art. 6 (1) (f) UK GDPR as the legal basis for the processing.
We delete or anonymise your personal data as soon as they are no longer necessary for the purposes for which we process them. The specific storage period depends on how you use our offer.
A revocation of consent to data processing can be made at any time informally by going into the user settings located in the profile page. You can then find the delete account button which will take you through the steps of removing the user data.
We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:
Email address
Last name
First name
As part of the registration process, the user's consent to the processing of this data is obtained.
Registration of the user is required for the provision of certain content and services on our website. Allows the user to be recognised on the platform by other users. However the name can be changed.
The legal basis for the processing of the data is Art. 6 (1) (a) UK GDPR if the user has given his consent.
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.This is the case for the data collected during the registration process if the registration is cancelled or modified on our website.
As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.
You must go into the user settings located in the profile page, you can then find the delete account button which will take you through the steps of removing the user data.
We offer our customers various payment options for processing their orders. Depending on the payment option, we transfer customers to the platform of the payment service provider in question. After completion of the payment process, we receive the customer's payment data from the payment service providers or our house bank and process these in our systems for billing and accounting purposes.
Further payment methods
We also offer payment with the following options: Google Pay, Apple Pay
The transmission of payment data to payment service providers serves to process payments, e.g. if you purchase a product and/or use a service.
The legal basis for data processing is Art. 6 (1) (b) UK GDPR, since the processing of the data is necessary for the execution of the concluded sales contract.
All payment data as well as data on possible chargebacks are only stored as long as they are required for payment processing and a possible processing of chargebacks and debt collection as well as for combating misuse.
Furthermore, payment data may be stored beyond this if and as long as this is necessary to comply with statutory retention periods or to prosecute a specific case of misuse.
Your personal data will be deleted at the end of the statutory retention period, i.e. after 10 years at the latest.
You can withdraw your consent to the processing of your payment data at any time by notifying the data controller or the payment service provider used. However, the payment service provider used may still be entitled to process your payment data if and as long as this is necessary for the contractual payment processing.
You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored. The data will be used exclusively for the processing of the conversation.
If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.
If the user has given consent, the legal basis for processing the data is Art. 6 (1) (a) UK GDPR. The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
The user has the possibility to withdraw the consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.
Email at contact@vollou.com
In this case, all personal data stored while establishing contact will be deleted.
We use plugins for various purposes. The plugins used are listed below: Use of Google AdSense
We use Google AdSense from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). With this service we place advertisements. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user's activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and operating system), data about the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data from advertising partners (in particular pseudonymised user IDs). Further information on the collection and storage of data by Google can be found here:
https://policies.google.com/privacy?hl=en-GB
Google evaluates the data in order to draw conclusions about your user behaviour with regard to the AdSense advertisements. The data can also be passed on to third parties if there is a legal obligation to do so or if the data is processed on behalf of Google.
The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (a) UK GDPR.
Your personal information will be stored for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.
You have the right to revoke your consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as a browser. Install NoScript
(https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com
Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?hl=en-GB
We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns.
Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user's activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use
of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.Further information on the collection and storage of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB
The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.
The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (a) UK GDPR.
Your personal information will be stored for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google's own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.
You have the right to revoke your consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. your IP address) to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com
Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?gl=EN&hl=en
We use the online map service Google Maps of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and the representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). We use the Google Maps plugin to visually display geographical data and embed it on our online presence. Through the use of Google Maps on our online presence, information about the use of our online presence, your IP address and addresses entered with the route plan function are transmitted to a Google server and stored there.
Further information on the collection and storage of data by Google can be found here:
https://policies.google.com/privacy?hl=en-GB
The use of the Google Maps plug-in serves to improve user friendliness and an appealing presentation of our online presence.
The legal basis for the processing of personal data is the user's given consent in accordance with Art. 6 (1) (a) UK GDPR.
Your personal information will be stored for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by law.
You have the right to revoke your consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the "Do Not Track" function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as a browser. Install NoScript
(https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com
Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?hl=en-GB
We use functionalities of the music streaming service Spotify of Spotify AB, Regeringsgatan 19, SE-111 53, Stockholm, Sweden (hereinafter referred to as Spotify). Spotify is a digital music, podcast and video streaming service that enables us to deliver our digital content through a variety of devices including computers, phones, tablets, speakers, televisions and cars. As a result, the following personal information is processed by Spotify:
Information about the type of Spotify Service subscription
Information about interactions with the Spotify Service
Identify your interests and preferences based on your use of the Spotify Service
User-generated content
URL information
Online identifiers including cookie data and IP addresses
Information about the device types used
Device attributes of devices on your Wi-Fi network that are available to connect to the Spotify Service
Not exact location determined from technical data
Motion generated or orientation generated mobile sensor data
Cookies and other similar technologies from Spotify are stored on your end device. For more information about Spotify's use of cookies, click here: https://www.spotify.com/us/legal/cookies-policy/
Spotify assures that the transfer of data to other countries is in accordance with the respective data protection laws and, for example, that the standard contractual clauses approved by the EU Commission are in place. Other recipients of the data are:
Service provider
Payment processor
Advertising Partner
Spotify Partner
Scientific research
Other Spotify affiliates
Law enforcement and data protection authorities
Buyers or prospective buyers
However, since we generally have no influence on the processing of your personal data by Spotify, the companies jointly responsible for our corporate identity, we cannot provide any binding information on the purpose and scope of processing your data. Further information on the collection and storage of data by Spotify can be found at:
https://www.spotify.com/us/legal/privacy-policy/
The use of Spotify allows us to provide audio formats such as music and podcasts.
The legal basis for data processing is Art. 6 (1) (f) UK GDPR. Our legitimate interest lies in the purposes of data processing mentioned under 2.
The data generated by the company website is not stored in our own systems. Your personal information will be stored for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.
You can prevent Spotify from collecting and processing your personal data by blocking the storage of third-party cookies on your computer, by using the "Do Not Track" feature of a supporting browser, by deactivating the execution of script code in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery
(https://www.ghostery.com) in your browser.
For further information on objection and removal options against Spotify, please visit:
https://www.spotify.com/us/legal/privacy-policy/
Description of the use of SDKs
We use SDKs to be able to provide function modules. For this purpose, the code used is embedded in the SDKs.
Third party libraries used:
Spotify
ACRCloud
Google Firebase
In order to operate the App, access to the following permissions is required:
Location services (iOS)
Social Media Account (iOS)
Microphone (iOS)
Camera (iOS)
Camera (Android)
Location (Android)
Microphone (Android)
Spotify account
Social media account can be used to login. Google and Apple login. Microphone is used to discover the music playing, camera is used to take photos and videos.
Spotify account is used to play music directly on Spotify and used to export the playlists' to. Location will be used when creating a session so the session can be added to the users map, however can be disabled.
The legal basis for the processing of personal data in the context of contacting us is the consent of the user pursuant to Art. 6 (1) p. 1 lit. a UK GDPR.
The processing of technical data serves to protect a legitimate interest of our company to provide a functional application for users and is therefore based on Art. 6 para. 1 p. 1 lit. f UK GDPR as the legal basis for processing.
Your personal information will be stored for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.
You have the right to revoke your consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
This privacy policy has been created with the assistance of DataGuard.