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Introduction & Scope
This Privacy Policy (“Policy”) describes how Keen Thinking Limited (“we”, “us”, “our”) collects, uses, stores and shares personal data when you use our mobile application (the “App”) — in addition to any data collected through our website. This Policy applies wherever we act as data controller in respect of you.
Please read this Policy carefully. By using the App, you agree to the processing of your data in accordance with this Policy.
If we make changes that we consider important, we will let you know — for example by posting the updated Policy on our website or via in-app notification.
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Controller and Contact Details
Controller: Keen Thinking Limited, registered at The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire, GL17 0DD, Company Number 04012805.
If you have questions or complaints about how we process your data, or want to exercise your rights, you can contact us at: info@simplicityinbusiness.com
Our Data Protection Officer is David Thornhill, 01594 372 111, david.thornhill@simplicityinbusiness.com
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What Data We Collect (via the App)
Depending on how you use the App, we may collect some or all of the following data types:
- Registration & account data: name, email address, phone number, user ID / username, password (encrypted).
- Profile data: any additional data you provide when creating or updating your profile.
- Device and technical data: device type, operating system, device identifiers, IP address, app version, crash logs or diagnostic data, usage data.
- Usage data: how you interact with the app (pages/screens visited, features used, timestamps), preferences, settings.
- Communications data: messages you send via the app, support requests, feedback, etc.
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Legal Basis & Purpose of Processing
We only collect and process your data where we have a valid legal basis under the UK GDPR (or applicable law), for example:
- Consent — when you have explicitly agreed (e.g. to receive marketing, to enable location tracking, etc.).
- Performance of a contract — to provide the App functionality or services you have requested (e.g. account creation, payments).
- Legitimate interests — where we have a legitimate business interest (e.g. improving the App, customer support, security) balanced against your rights.
We use your data for the following purposes:
- To provide and maintain the App’s core functionality.
- To manage your account, authenticate users, and provide customer support.
- To improve and personalise your user experience (e.g. app usage analytics, diagnostics).
- To send communications where relevant (e.g. notices, updates), if you have consented.
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Data Sharing and Disclosures
We may share your data with third parties only in the following circumstances:
- With service providers or partners who help us operate the App (e.g. cloud hosting, payment processors, analytics providers) — always under contract, with confidentiality and data security obligations.
- If required by law or to respond to lawful requests (e.g. fraud prevention, investigations, regulatory compliance).
- With your consent (e.g. for optional features, third-party integrations).
We will not sell or lease your personal data to third parties for marketing or commercial purposes.
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Data Retention
We will retain your personal data only for as long as necessary to fulfil the purposes set out above, or to comply with our legal obligations (for example, accounting or regulatory record-keeping), whichever is longer.
We will delete or anonymise personal data when it is no longer needed. If you ask us (see below), we will delete your data sooner — subject to any legal or regulatory retention requirements.
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Data Security
We implement reasonable technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration or destruction. This may include encryption, pseudonymisation, access controls, secure storage, and regular security reviews. We follow the principle of “privacy by design and by default.” Sprintlaw UK+2TermsFeed+2
However, no system is completely secure — if you believe your data has been compromised, please contact us immediately.
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Your Rights
Under GDPR (and UK data protection law) you have certain rights, including:
- The right to access the personal data we hold about you.
- The right to rectify or update incorrect or incomplete data.
- The right to request erasure (“right to be forgotten”) of your data.
- The right to restrict or object to certain types of processing (e.g. profiling, analytics).
- The right to data portability (where applicable).
- If processing is based on consent — the right to withdraw consent at any time, without affecting previous lawful processing.
- The right to lodge a complaint with a supervisory authority (e.g. the Information Commissioner’s Office) if you believe we have breached data protection laws. GDPR+1
To exercise any of these rights, please contact us at info@simplicityinbusiness.com
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Cookies & Tracking / Analytics / Third-party Libraries
If the App uses cookies, local storage, or similar tracking technologies (e.g. for analytics, advertising, crash reporting), we will inform you before these are set/used and — where required — ask for your consent. This is required under the Privacy and Electronic Communications Regulations (PECR) if the App stores or reads information on the user’s device. LegalVision UK+2Harper James+2
We will provide details of what tracking it is, who runs it, and how you can opt out.
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International Data Transfers (if applicable)
If we transfer your data outside the UK or EEA (for example to cloud servers or service providers abroad), we will only do so where appropriate safeguards are in place (e.g. standard contractual clauses, adequacy decisions) — and we will inform you of this. GDPR+1
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Updates to this Policy
We may update this Policy from time to time. The “Last updated” date will be shown at the top. If we make material changes, we will notify you (e.g. via the App or by e-mail) and seek any required consents again.
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Contact & Complaints
If you have any questions or concerns about this Policy or how we process your personal data, or if you want to exercise your rights, please contact us by calling 01594 372 111 or by email at info@simplicityinbusiness.com
If you believe we have not handled your data properly, you have the right to lodge a complaint with the supervisory authority (e.g. ICO).