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This policy describes the information that we process to support Striver and other products and features
offered by Tru Challenge Limited (Products).A. WHAT KINDS OF INFORMATION DO WE COLLECT?
To provide our Products, we must process information about you. Broadly this falls into three
categories-1. What you and others do and provide
• Information and content you provide. We collect the content, communications and other information you provide when you use our Products, including when you sign up for an account, create or share content and message or communicate on our platform. This can include information in or about the content that you such as the location of a video or the date a file was created. Our systems automatically process content and communications that you and others provide.
• Networks and connections. We collect information about the people, accounts and groups that you are connected to and information as to how you interact with them across our Products.
• Your usage. We collect information about how you use our Products, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities.
• Things others do and information they provide about you. We also receive and analyse content, communications and information that other people provide when they use our Products. This can include information about you, such as when others share or comment on a video or photo uploaded by you.2. Device information
As described below, we collect information from and about the computers, phones, and other web- connected devices you use that integrate with our Products. We combine this information across different devices you use. For example, we use information collected about your use of our Products on your phone to better personalise the content (including ads) or features that you see when you use our Products on another device, such as your laptop or tablet, or to measure whether you took an action in response to an ad that we showed you on your phone or on a different device.
Information we obtain from these devices includes:
• Devices: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type and plugins of your device.
• Device operations: information about operations and behaviours performed on any of your devices.
• Device signals: Bluetooth signals, information about nearby Wi-Fi access points, beacons and mobile phone masts.
• Identifiers: unique identifiers, device IDs and other identifiers, such as from apps or accounts that you use.
• Device settings: information you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos.
• Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address and connection speed.
• Cookie data: data from cookies stored on your device, including cookie IDs and settings.3. Partner Information
Advertisers and partners can send us information about you that they collect. They receive your data when you use their services. We require each of these partners to have lawful rights to collect, use and share your data before providing us with any data.B. HOW DO WE USE THIS INFORMATION?
We use the information that we have to provide and support our Products. We do this in the following ways:-1. Provision and improvement of our Products
We use the information that we have to deliver our Products, including to personalise features and content and make suggestions to you that you may be interested in challenges that you may want to participate in. To create personalised Products that are unique and relevant to you, we use:-
• your connections, preferences, interests and activities based on the data that we collect and learn from you and others;
• how you use and interact with our Products; and
• the people, places or things that you're connected to and interested in on our Products
We use location related information (such as your current location, where you live and the places you like to go to provide, personalise and improve our Products.
We use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
We use the information we have about you (including information about your interests, actions and connections) to select and personalise ads, offers and other sponsored content that we show you.2. Measurement, analytics and other business services
We use the information we have (including your activity on our Products) to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps and services.3. Promoting safety, integrity and security
We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security in relation to our Products.4. Communication
We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our Policies and Terms of Use. We also use your information to respond to you when you contact us.5. Researching and Innovation
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.C. HOW IS THIS INFORMATION SHARED?
Your information is shared in the following ways:1. People and accounts
With those people, organisations and audiences you share and communicate with using our Products.2. Third-party partners
We work with third-party partners who help us provide and improve our Products. We do not sell any of your information to anyone. We never will. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with:• Advertisers
We provide advertisers with reports about the kinds of people seeing their ads and how their ads are
performing, but we never share information that personally identifies you unless you give us permission. • Measurement partners
We can share information about you with companies that aggregate it to provide analytics and measurement reports to us and our partners.
• Vendors and service providers
We provide information and content to service providers who support our business, such as by providing technical infrastructure services, analysing how our Products are used, providing customer services or conducting surveys.
• Researchers and academics
We also provide information and content to research partners and academics to conduct research that advances scholarship and innovation that supports our business or mission and enhances discovery and innovation on topics of general social welfare, public interest, health and well-being.• New owner
If the ownership or control of all or part of our Products changes, we may transfer your information to
the new owner
• Law enforcement
We share information with law enforcement agents or in response to legal requests in the circumstances outlined below.D. WHAT IS OUR LEGAL BASIS FOR PROCESSING DATA?
We collect, use and share the data that we have in the ways described above:• as necessary to fulfil our Terms of Use:
• consistent with your consent, which you may revoke at any time on the Striver settings;
• as necessary to comply with our legal obligations;
• to protect your vital interests, or those of others;
• as necessary in the public interest; and
• as necessary for our legitimate interests, including our interests in providing an innovative, personalised, safe and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.E. HOW CAN YOU EXERCISE YOUR RIGHTS PROVIDED UNDER THE GDPR?
Under the General Data Protection Regulation, you have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:• the right to object to our processing of your data for direct marketing, which you can exercise by using the "unsubscribe" link in such marketing communications; and
• the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.F. DATA RETENTION, ACCOUNT DEACTIVATION AND DELETION
We store data until it is no longer necessary for the purposes of providing our Products or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.When you delete your account, we delete anything that you have posted, such as your videos, photos and status updates, and you won't be able to recover this information later. Information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using our Products, you can deactivate your account instead. To delete your account at any time, please visit the Striver settings.G. HOW DO WE RESPOND TO LEGAL REQUESTS OR PREVENT HARM?
We access, preserve and share your information: -• In response to a legal request from regulators, law enforcement or others, if we believe in good faith that the law requires us to do so. We can also respond to legal requests when we believe in good faith that the response is required by law in the relevant jurisdiction, if it affects users in that jurisdiction and if it is consistent with internationally recognised standards.
• When we believe in good faith that it is necessary to:-
o detect, prevent and address fraud, unauthorised use of our Products, breaches of our Terms of Use or Policies, or other harmful or illegal activity;
o to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory enquiries; or
o to prevent death or imminent bodily harm.
Information that we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible violations of our Terms of Use or Policies, or otherwise to prevent harm. We also retain information from accounts disabled for breaches of our Terms of Use for at least a year to prevent repeat abuse or further breaches.H. HOW WILL WE NOTIFY YOU OF CHANGES TO THIS POLICY?
We will notify you before we make changes to this Policy and give you the opportunity to review the revised Policy before you choose to continue using our Products.I. HOW TO CONTACT US WITH QUESTIONS
If you have questions about this policy, you can contact us as described below.
The data controller responsible for your information is Tru Challnge Limited, which you can contact on line or by sending an email to [email protected]J. WHO WE ARE
Tru Challenge Limited, the owner and operator of Striver, is a company registered in England & Wales with company number 10167355 and with registered address at A and L Suite, 1-3 Hop Exchange, 24 Southwark Street, London, SE1 1TY.K. COMPLAINTS
You also have the right to lodge a complaint with Tru Challenge Limited's lead supervisory authority, the Information Commissioner’s Office at https://ico.org.uk/global/contact-us/
Created: 7th October 2022