We take your privacy seriously and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, share and protect personal data when you use the Instant Agony Aunts website, mobile applications, messaging services and related features (collectively, the "Services").
This Privacy Policy should be read together with our Terms and Conditions and Cookie Policy. It applies to users of our Services, including customers, registered members, visitors and, where relevant, Agony Aunts and Advisors using our platform.
We process personal data in accordance with applicable data protection law, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018.
1. Who We Are
Instant Agony Aunts operates an online platform through which users can communicate with independent Agony Aunts and Advisors.
For the purposes of applicable data protection law, the operator of Instant Agony Aunts is the controller of personal data processed in connection with the Services, except where another party acts as an independent controller.
Questions about this Privacy Policy or the way we process your personal data may be submitted through the Contact Us page on our website or mobile application.
2. Personal Data We Collect
"Personal Data" means information relating to an identified or identifiable individual. The information we collect depends upon how you use our Services.
2.1 Account and Profile Information
When you create or maintain an account, we may collect information including:
- Your name or display name;
- Username;
- Email address;
- Telephone or mobile number, where provided;
- Password and authentication information;
- Profile information;
- Profile photographs or other images;
- Date of birth or age information, where required;
- Account preferences and settings; and
- Any other information you choose to provide through your account.
2.2 Messages and Communications
When you use our messaging or communication Services, we process information relating to those communications. This may include message content, the participants in a conversation, timestamps, delivery information and other associated metadata.
Conversations with Agony Aunts or Advisors may contain information that you voluntarily disclose about your personal circumstances, relationships, family, work, emotions or other matters. Because conversations may involve sensitive subjects, you should carefully consider the information you choose to disclose.
2.3 Special Category and Sensitive Information
Depending on what you choose to discuss, your messages may contain information concerning matters such as your physical or mental health, racial or ethnic origin, religious or philosophical beliefs, political opinions, sex life or sexual orientation. Some of this information may constitute "special category data" under UK data protection law.
We do not require you to disclose special category information merely to use ordinary messaging functionality. Where you voluntarily include such information in communications, we will process it only where we have an appropriate lawful basis and, where required, an additional condition for processing under applicable data protection law.
2.4 Transaction and Payment Information
When you purchase Services or add funds to your account, we may process transaction information including:
- The amount paid;
- Currency;
- Date and time of the transaction;
- Services purchased;
- Transaction and payment reference numbers;
- Payment status;
- Refund and chargeback information; and
- Limited payment-related information supplied to us by the relevant payment provider.
Payments may be processed by third-party providers such as Stripe, PayPal, Apple, Google or other payment processors. We generally do not receive or store your complete payment card number when payment is processed directly by such providers.
2.5 Technical and Device Information
When you access the Services, we may automatically collect technical information such as:
- IP address;
- Browser type and version;
- Device type and model;
- Operating system;
- Mobile application version;
- Device identifiers and application identifiers;
- Language and time-zone information;
- Approximate location derived from an IP address;
- Pages and features accessed;
- Dates and times of access;
- Referral information;
- Crash and diagnostic information; and
- Security and authentication logs.
2.6 Customer Support and Complaints
If you contact us, make a complaint, report another user or Advisor, request assistance or otherwise communicate with us, we may collect your correspondence and any information necessary to investigate and respond to the matter.
2.7 Information About Advisors
Where you register or operate as an Agony Aunt or Advisor, we may collect additional information necessary to administer your relationship with the platform. This may include identity and contact information, profile information, payment or payout details, verification information, tax or business information where applicable, performance information and records relating to your use of the platform.
3. How We Collect Personal Data
We may collect personal data:
- Directly from you when you register or update your account;
- When you use our website or mobile applications;
- When you send or receive messages;
- When you make a payment or purchase;
- When you contact customer support;
- When you submit a complaint or report;
- Automatically through cookies, application technologies, server logs and similar technologies;
- From payment processors, app stores and other service providers;
- From Advisors or other users where necessary to investigate a complaint, safety matter or suspected breach of our Terms; and
- From publicly available or lawful third-party sources where appropriate.
4. How We Use Your Personal Data
We may use personal data for the following purposes:
- Creating, administering and securing your account;
- Providing the Services;
- Connecting users with Agony Aunts and Advisors;
- Processing and delivering messages and other communications;
- Processing purchases, payments, account balances, refunds and payouts;
- Providing customer support;
- Responding to enquiries, reports and complaints;
- Preventing and detecting fraud, spam, abuse and other prohibited activity;
- Protecting the security and integrity of our Services;
- Investigating suspected breaches of our Terms and Conditions;
- Moderating content and communications where appropriate;
- Complying with legal and regulatory obligations;
- Establishing, exercising or defending legal claims;
- Improving and developing our website, applications and Services;
- Understanding how our Services are used;
- Diagnosing technical problems and monitoring performance;
- Measuring the effectiveness of features and marketing;
- Communicating important information about your account or the Services; and
- Sending marketing communications where permitted by law.
5. Our Lawful Bases for Processing
UK data protection law requires us to have a lawful basis for processing personal data. The lawful basis we rely upon will depend upon the information and the reason for processing it.
5.1 Performance of a Contract
We process personal data where necessary to enter into or perform our contract with you, including creating your account, providing messaging functionality, delivering paid Services and administering transactions.
5.2 Legitimate Interests
We may process personal data where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and interests. These interests may include operating and improving the Services, preventing fraud, maintaining security, handling complaints, protecting users and Advisors and protecting our legal rights.
5.3 Legal Obligations
We may process information where necessary to comply with a legal or regulatory obligation, court order or other lawful requirement.
5.4 Consent
In some circumstances we rely upon your consent, including for certain cookies, marketing activities or processing where consent is otherwise required by law. Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.
5.5 Special Category Data
Where we process special category personal data, we will rely upon an appropriate condition permitted by applicable data protection law in addition to having a lawful basis for processing.
6. Messages, Monitoring and Moderation
Messages sent through our Services are processed as necessary to deliver and operate the messaging Service.
We may access, review or use automated systems to analyse communications where reasonably necessary and legally permitted for purposes including:
- Investigating complaints and reports;
- Detecting fraud, scams, spam or abuse;
- Enforcing our Terms and Conditions;
- Protecting users, Advisors and our Services;
- Investigating technical problems;
- Complying with legal obligations; and
- Responding to lawful requests from competent authorities.
We do not represent that every conversation is actively monitored. The availability of moderation or investigation tools does not mean that every communication will be reviewed.
7. Automated Processing and Artificial Intelligence
We may use automated technologies to assist with security, fraud detection, spam prevention, content moderation, service improvement, analytics and other operational functions.
Where we use automated processing that produces legal effects or similarly significantly affects you, we will provide the information and safeguards required by applicable data protection law.
We will not use the content of private conversations to train third-party general-purpose artificial intelligence models unless we have a lawful basis to do so and provide any notice or obtain any consent required by applicable law.
8. Analytics and Measurement
We may use analytics and measurement technologies to understand how visitors and registered users interact with our Services, identify technical problems, measure performance and improve our products.
These services may collect information such as device identifiers, IP addresses, application activity, browser information, pages visited, interactions, approximate location and diagnostic information.
8.1 Google Services
We may use Google products and services, including Google Analytics, Google Analytics for Firebase, Firebase and related Google technologies on our website and/or mobile applications.
Depending upon the Google service being used, Google may process device information, identifiers, IP addresses, application activity, usage information, diagnostic data and other technical information in accordance with Google's applicable terms and privacy policies.
9. Cookies and Similar Technologies
Our website may use cookies and similar technologies. Our mobile applications may use software development kits ("SDKs"), device identifiers, local storage and similar technologies.
These technologies may be used to:
- Keep you signed in;
- Remember preferences;
- Maintain security;
- Prevent fraud;
- Provide essential functionality;
- Measure usage and performance; and
- Support analytics and marketing where permitted.
Where consent is legally required for non-essential cookies or similar technologies, we will request consent before using them.
Further information about the cookies and similar technologies we use, including available choices, is provided in our Cookie Policy.
10. Marketing Communications
Where permitted by law, we may contact you about Instant Agony Aunts, account features, promotions, new Services or other information that may be relevant to you.
You can unsubscribe from marketing emails by using the unsubscribe facility provided in the relevant communication or by changing available account preferences.
Even if you opt out of marketing, we may continue to send essential service communications concerning matters such as your account, transactions, security, legal notices or changes to the Services.
11. Push Notifications
Our mobile applications may send push notifications if you enable them. Notifications may include account information, message notifications, service updates or, where permitted, promotional communications.
You can control push notification permissions through your device settings and, where available, through settings within the application.
12. Sharing Your Personal Data
We do not sell your personal data.
We may share personal data with third parties where reasonably necessary for the purposes described in this Privacy Policy.
12.1 Service Providers
We may use third-party providers to assist with services including:
- Website and application hosting;
- Cloud infrastructure;
- Database and data storage;
- Email delivery;
- SMS and communications;
- Push notifications;
- Authentication;
- Payment processing;
- Fraud prevention and security;
- Analytics;
- Customer support; and
- Technical maintenance.
Where a provider processes personal data on our behalf, we require appropriate contractual and security safeguards where required by law.
12.2 Payment Providers and App Stores
Payment information may be shared with or independently collected by payment processors and application marketplace providers including Stripe, PayPal, Apple and Google, depending upon the payment method you select.
These organisations may process certain information as independent controllers under their own privacy policies.
12.3 Agony Aunts and Advisors
Information you choose to communicate to an Advisor will necessarily be made available to that Advisor for the purpose of providing the requested conversation or Service.
Advisors are required to use information obtained through the platform appropriately and in accordance with applicable platform rules and legal obligations.
12.4 Legal and Regulatory Disclosures
We may preserve or disclose personal data where we reasonably believe this is necessary to:
- Comply with applicable law;
- Comply with a court order, warrant or other binding legal process;
- Respond to a lawful request from law enforcement or another competent authority;
- Prevent, investigate or detect crime or fraud;
- Protect the rights, property or safety of users, Advisors, us or another person;
- Establish, exercise or defend legal claims; or
- Meet regulatory or safeguarding obligations.
12.5 Business Transfers
If our business, company, platform or relevant assets are sold, merged, reorganised, financed or transferred, personal data may be disclosed to prospective purchasers, professional advisers, investors or other relevant parties and may subsequently be transferred as part of that transaction, subject to appropriate confidentiality and data protection safeguards.
13. International Transfers
Some of our service providers may process personal data outside the United Kingdom.
Where personal data is transferred internationally, we will take appropriate steps required by applicable data protection law. Depending upon the destination and circumstances, these safeguards may include adequacy regulations, approved contractual protections such as the UK International Data Transfer Agreement or UK Addendum, or another lawful transfer mechanism.
14. Data Security
We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
Depending upon the information and system involved, safeguards may include encryption, access controls, authentication measures, network security, logging, backups, monitoring and restrictions on access to personal data.
No website, application, electronic communication or data-storage system can be guaranteed to be completely secure. You are responsible for keeping your account credentials confidential and should notify us promptly if you believe your account has been compromised.
15. How Long We Keep Your Data
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required or permitted by law.
Retention periods may vary depending upon the type of information and may take into account:
- The duration of your account;
- The need to provide the Services;
- Financial, accounting and tax obligations;
- Fraud and abuse prevention;
- Security requirements;
- Complaints and disputes;
- Chargebacks and payment disputes;
- Potential or actual legal claims; and
- Legal and regulatory requirements.
Information may be deleted, anonymised or retained in a restricted form when it is no longer required for ordinary operational purposes.
16. Account Closure and Deletion
You may request closure or deletion of your account using functionality made available through the Services or by contacting us.
Account deletion does not necessarily result in the immediate deletion of every record associated with your account. We may retain information where necessary to comply with legal obligations, prevent fraud, resolve disputes, process chargebacks, enforce agreements, protect users or establish, exercise or defend legal claims.
Where information must be retained after account closure, access may be restricted and the information will be retained only for an appropriate period.
17. Your Data Protection Rights
Subject to applicable law and relevant exemptions, you may have rights including:
- The right to be informed about how your personal data is processed;
- The right to request access to personal data we hold about you;
- The right to request correction of inaccurate or incomplete information;
- The right to request deletion of personal data in certain circumstances;
- The right to request restriction of processing in certain circumstances;
- The right to object to certain processing;
- The right to data portability in applicable circumstances;
- Rights relating to certain automated decision-making and profiling; and
- The right to withdraw consent where processing is based upon consent.
These rights are not absolute. In some circumstances we may lawfully continue processing or retaining information despite a request.
17.1 Exercising Your Rights
You can submit a data protection request through our Contact Us page.
We may request reasonable information to confirm your identity before responding to a request. This is intended to prevent personal data from being disclosed to an unauthorised person.
18. Complaints About Our Use of Personal Data
If you have concerns about how we process your personal data, please contact us first so that we have an opportunity to investigate and respond.
You also have the right to complain to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection matters. Your right to contact the ICO is not affected by contacting us first.
19. Children
The Services are intended only for persons aged 18 or over. We do not knowingly permit persons under the age of 18 to create accounts or use our messaging Services.
If we become aware that an account is being operated by a person under 18, we may suspend or terminate the account and take appropriate steps concerning the associated personal data.
20. Fraud Prevention, Safety and Abuse
We may process account, transaction, device, network, communication and usage information to identify and investigate fraud, scams, abusive behaviour, unauthorised access, payment abuse and violations of our Terms.
Where reasonably necessary, we may restrict an account or transaction while suspected fraud, security incidents or other prohibited activity is investigated.
21. Third-Party Websites and Services
Our Services may contain links to websites, applications or services operated by third parties.
We are not responsible for the privacy practices, security or content of independent third-party services. You should review the applicable privacy policy before providing personal data to a third party.
22. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our Services, technology, business practices, legal obligations or regulatory requirements.
The latest version will be published on our website and/or mobile application. Where a change materially affects the way we process your personal data, we will provide additional notice where required by law.
23. Contact Us
If you have questions about this Privacy Policy, wish to exercise your data protection rights or have a complaint concerning the processing of your personal data, please contact us through the Contact Us page on our website or mobile application.
24. Further Information
This Privacy Policy should be read together with our Terms and Conditions and Cookie Policy, which provide additional information concerning your use of Instant Agony Aunts and the technologies used through our Services.