Privacy Policy

 

Last Updated: Mon 5 Sep, 2022

We built Speedy Clean to earn your trust by design.  Privacy is a top priority.  That’s why Speedy Clean scours your contacts, calendar and photo data on your device, without using the Internet, by default.  That’s why you can create an account and manage your subscription through your app store, without providing your contact and payment details to us. 

This Privacy Notice describes how we, and the Speedy Clean app, treat all data processed when you use Speedy Clean, not just ‘personal’ information as defined by law.      

This Privacy Notice applies to use of the Speedy Clean app and services operated by We Optimize Limited, a U.K. company with registration number 14162466 (“we” or “us”), under the Speedy Clean brand.  For simplicity, we refer to all of these as our “Services” below.  By contrast, we use “Speedy Clean” below to refer to the Speedy Clean app for iOS and Android

Please read the Privacy Notice carefully and make sure you’re comfortable with our privacy practices.  If you do not accept and agree to this Privacy Notice, then you must not access or use the Services.

Finally, please note that our Terms of Use[1] and its incorporated documents also apply to your use of our Services.  Capitalized terms used but not defined in this Privacy Notice are defined in the Terms of Use.

1.       Who We Are

(a)     The data controller responsible for your information under this Privacy Notice is:

We Optimize Limited
Larch House,
Parklands Business Park,
Denmead,
Hampshire,
PO7 6XP,
United Kingdom

We Optimize Limited is the Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679)) (“GDPR”) and the UK General Data Protection Regulation, tailored by the Data Protection Act 2018.

We Optimize Limited is the Business for the purposes of the California Consumer Privacy Act (“CCPA”).

2.       Scope of this Privacy Notice

(a)     A quick note on terminology

To be comprehensive about how we use your data, we refer to a few different concepts in this Privacy Notice, always using capital letters.  Here are those concepts:

(i)       “Feature Data” means contacts, calendars and photos data on your device that the Speedy Clean app processes.  Although Feature Data may include personal information about you and other people, we exclude Feature Data from the “Personal Information” definition in this Privacy Notice because we do not collect or retain it.  See Section 3(a) for more details

(ii)      “Personal Information” means information, other than Feature Data, that would be defined as ‘personal data’ under GDPR or ‘personal information’ under CCPA.  Please note that depending on where you live, applicable law may define this concept differently.  It may not define this concept at all.

(iii)    “External Service” means a third-party account (e.g., Facebook, Google or Apple) used to create an Account with us or manage a Subscription.

(b)     Personal Information regarding children

Only individuals who can enter a legally binding a contract may use the Services.  Accordingly, we do not intentionally gather any Personal Information about individuals who are under the age of eighteen (18).  If you know or suspect that a user of our Services is under the age of 18, please contact us immediately.

(c)     Changes to this Privacy Notice

We may modify this Privacy Notice from time to time to reflect changes in applicable law or updates to the Services.  We will notify you if such change materially affects your rights under this Privacy Notice.  Changes will not apply retrospectively and, unless the change is required immediately for legal reasons, notice of the modified terms will be provided a reasonable period prior to the changes taking effect. 

3.       Data and Personal Information we process.

(a)     Feature Data

(i)       Except as described in this Section 3(a), all Feature Data is processed by Speedy Clean on your device, without using any Internet software or resources.  Speedy Clean can only access Feature Data with your permission.  Speedy Clean only processes Feature Data for the purpose of providing in-app features and functionality, like highlighting and deleting duplicate photos. 

(ii)      We do not receive Feature Data.  Accordingly, no Feature Data is associated with your Account or use of the Services.

(iii)    Some Speedy Clean features are only available if you consent to the processing of related Feature Data by third-party services through your device’s network connection (“Internet Software”).  Speedy Clean will notify you and obtain your consent before you use a Speedy Clean feature requiring the use of Internet Software.  For example, use of Speedy Clean’s ‘Places’ scan of your photos requires processing the geographic coordinates of your photo metadata through Apple’s online geocoding service to convert the coordinates to familiar place names. 

(b)     Personal Information you give us

Because your Account is created through an External Service, we will only receive the Personal Information that the External Service provider, as configured by you, provides to us on your behalf.   As a general matter, we do not require your Account to contain any Personal Information, but you may choose to share information like your name, email address or telephone number when you create your Account.  You may also give us additional Personal Information while using the Services – for example, you may tell us your name when initiating a support enquiry if we do not have it.

(c)     Data we collect

We also collect and store data as you use the Services, and we may collect limited Personal Information when you interact with us in certain ways.  See below for more details:

(i)       Personal Information.  We may collect additional Personal information as you use the Services, such as when you:

(A)     update your Account with Personal Information;

(B)     communicate with us by email or other electronic communication;

(C)     download new apps, products or services from our affiliated businesses; and

(D)     use a new device (to the extent you have given us Personal Information through your existing Account).

(ii)      Usage data.  Using the Services generates data about your activity, for instance how you use them (e.g., when you logged in, features you’ve been using, actions taken, information shown to you).  We also store data about the Services you purchase, such as the activation code, date of purchase, and data relating to any support issue.

(iii)    Device data.  We collect data from and about the device(s) you use to access our Services, including hardware and software data such as IP address, device ID and type, and Speedy Clean settings, characteristics and crashes.

(d)     Data we receive from others

(i)       External Service.  You may decide to share Personal Information with us when you use your existing External Service account to buy a Subscription to Speedy Clean.

4.       How we use data

(a)     The main reason we use your data is to deliver and improve our Services. Additionally, we use your info to communicate with you.  Here are the reasons we use your data, together with practical examples:

(i)       To provide our Services to you, including via your Account

(A)     Create and manage your Account

(B)     Provide you with customer support and respond to your requests

(C)     Communicate with you about our Services

(ii)      To manage your Account or fulfil your Subscriptions

(A)     Register you on the Services and allow you to purchase Subscriptions

(B)     Administer your Account on new features and apps

(C)     To improve our Services and develop new ones

(D)     Review interactions with support teams to improve our quality of service

(iii)    Develop new content and services

(A)     To operate advertising and marketing campaigns

(B)     Communicate with you about products or services that we believe may interest you

(iv)    To prevent, detect and fight fraud and other illegal or unauthorized activities

(A)     Find and address ongoing, suspected or alleged violations of our Terms of Use

(B)     Retain data related to violations of our Terms of Use to prevent against recurrences

(C)     To ensure legal compliance and assist law enforcement

(b)     Legal Bases

If we process your Personal Information as described in this Privacy Notice, we rely on the following legal bases:

(i)       Provide our Services to you: The reason we process your Personal Information for purposes 4(a)(i)-(iii) above is to perform the contract that you have with us. For instance, if you order a Subscription from us, we use your Personal Information to complete and maintain the Subscription. 

(ii)      Legitimate interests: We process your Personal Information for purposes 4(a)(iii) and 4(a)(iv) above based on our legitimate interest.  For instance, we analyze users’ behaviour on our Services to continuously improve our offerings, we suggest offers we think might interest you and promote our own Services, we process data where necessary to enforce our rights, assist law enforcement and enable us to defend ourselves in the event of a legal action.

(iii)    Comply with applicable laws and regulations: We process your Personal Information for purpose 4(a)(iv) above where it is necessary for us to comply with applicable laws and regulations and evidence our compliance with applicable laws and regulations. For example, we retain traffic data and data about transactions in line with our accounting, tax and other statutory data retention obligations and to be able to respond to valid access requests from law enforcement.

(iv)    Consent: If you choose to provide us with other Personal Information not addressed by the foregoing legal bases, including any that may be considered ‘special’ or ‘sensitive’ under applicable law, you’re consenting to our processing of that Personal Information in accordance with this Privacy Notice.  You may withdraw your consent by adapting your settings or contacting us.

5.       How long we retain Personal Information

(a)     If we have any Personal Information about you, we will only retain it for as long as we need it for legitimate business purposes (as laid out in Section 4) and as permitted by applicable law.  When you cancel your Subscription, your Account will be closed at the time your Subscription expires.  We will then delete your Account and any Personal Information associated with it, as laid out below:

(i)       We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for up to ten years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction and “traffic data” / logs for up to one year to comply with legal data retention obligations.

(ii)      We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data for up to five years to support our support decisions, enforce our rights and enable us to defend ourselves in the event of a claim, information on the existence of past Accounts and Subscriptions, which we delete no later than three years after the closure of your Account to ensure proper and accurate financial forecasting and reporting, and data necessary to prevent users who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.

(iii)    Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim or dispute requiring us to keep information (in particular if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).

6.       Outside Websites

The Services may provide links or content from third-party web platforms and sites (“Outside Websites”).   Outside Websites have separate and independent privacy policies, notices and terms of use which govern your use of such websites and their use of any information they collect.  We recommend you read these policies carefully.  We expressly disclaim all liability for any Personal Information you provide to any Outside Websites.

7.       Cookies

The Services use “cookies” and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our mobile app.  We use cookies to gather general information about your use of the Services, the configuration of your device and your device’s interaction with the Services, which may be stored within Speedy Clean’s local log files and/or provided to the Services.  We use this information to understand traffic and feature utilization, enabling us to improve the Services and provide the best customer experience possible.

You may disable and/or control cookies and trackers using your device-level settings.  See your External Service’s account pages for more information on how to control device-level settings.

(a)     Strictly necessary cookies

These cookies are essential in order to enable you to use the Services.  Without these cookies, Services you have asked for, like security or e-billing, cannot be provided.

(b)     Performance cookies

These cookies collect information about how you use the Services.  These cookies don’t collect information that identifies you and are only used to improve how the Services works.

(c)     Functionality cookies

These cookies allow the Services to remember choices you make, such as the configuration of your computer, to provide enhanced, more personal features.

(d)     Other Technologies

We may also use other Internet technologies, such as web beacons or pixel tags and other similar technologies, to deliver or communicate with cookies and analyze your use of the Services.  We also may include web beacons in e-mail messages so that we know when you have opened an email message received from us.

8.       How We Protect Your Data

(a)     General

We Optimize Limited has security measures in place to protect against the loss, misuse, and alteration of your data.  Personal Information provided to us is stored in secure facilities with access restricted to authorized personnel only.  Although we make good faith efforts to store Personal Information in a secure operating environment that is not accessible to unauthorized users, we cannot guarantee complete security.

(b)     Secure Payments

All Subscriptions are made available through, and all payments are processed by, External Services.  Please refer to the applicable External Service for more information about their practices with respect to your Personal Information and payment processing.

9.       Rights of Access, Correction, Erasure, and Restriction

(a)     Depending on your location, applicable law may give you the right to:

•         Request access to your personal information (commonly known as a ‘data subject access request’).  This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

•         Request correction of the personal information that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected.

•         Request erasure of your personal information.  This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

•         Object to processing of your personal information 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.  You also have the right to object where we are processing your personal information for direct marketing purposes.

•         Request the restriction of processing of your personal information.  This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

•         Request the transfer of your personal information to another party.

If you wish to exercise any of these rights, or enquire about which rights you may have under applicable law, please contact enquiries@getspeedyclean.com.

(b)     No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.

Alternatively, we may refuse to comply with the request in such circumstances.

(c)     What we may need from you

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 information is not disclosed to any person who has no right to receive it.

(d)     Time limit to respond

We try to respond to all legitimate requests within one month.  Occasionally it may 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.

10.    Your EU Data Protection Rights

Some Services features are performed by Internet Software from providers based outside the EEA and/or using systems outside the EEA.  When using Internet Software features, processing of your Personal Information (if any) may involve a transfer of Personal Information outside the EEA.

Whenever we permit the processing of EEA Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•         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 European Commission.  For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

•         Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has under applicable EEA law.  For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact enquiries@getspeedyclean.com if you want further information on the specific mechanism used by us when transferring your personal data out of Adequate Jurisdictions.

11.    Dispute Resolution

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to us at the address given below.  We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Notice.

If we are unable to resolve your complaint, you can escalate the issue in accordance with the dispute resolution procedure set out in the Terms of Use.

If your Personal Information is held by our European Controller or you reside in California, you have the right to make a complaint at any time to the data protection authority in your jurisdiction.  If you are unaware of contact information for your data protection authority, please contact us and we will provide it to you. 

12.    Our Contact information

If you have any questions or comments about this Privacy Notice, please contact us at enquiries@getspeedyclean.com or by mail to:

We Optimize Limited
Larch House,
Parklands Business Park,
Denmead,
Hampshire,
PO7 6XP,
United Kingdom

Please note that any enquiries regarding subscriptions, such as cancellations or refunds, must be directed to the app store through which you purchased your subscription.  See our Terms of Use for more information.

 

© We Optimize Limited