Introduction

In this notice, we explain how we collect, use, share and protect your personal information when you use the “Zoteria App”.
The “Zoteria App” is a public mobile app which enables the user to submit hate crime reports to Galop. The app is sponsored and supported by the Vodafone Foundation and Stonewall. Vodafone provide the app hosting and support.
Together, the Vodafone Foundation and Galop are “joint controllers” of the personal information that’s collected as part of the Zoteria App – this means that we jointly decide how and why the personal information is used, and we are all jointly responsible for it. If you would like to find out more about our relationship as joint controllers, please contact us using the details in the ‘Contact details’ section below.
The “Zoteria App” is aimed at those 18 and over.

About us

Our details as joint controllers are as follows:

Galop: LESBIAN, GAY AND BISEXUAL ANTI - VIOLENCE AND POLICING GROUP

Our registered office is at

8-9 Talbot Court
City of London
London
EC3V 0BP

Vodafone Foundation: Vodafone Foundation is a Charity registered with the Charity Commission for England & Wales (charity number 1193984) & a Company Limited by Guarantee registered in England and Wales (company number 13199169). Registered Office:
Our registered office is at VodafoneFoundation, 1 Kingdom Street, London, W2 6BY.
In this privacy notice:

  • “we/us” means Galop and the Vodafone Foundation
  • “third party” means someone who is not you or us;
  • “Stonewall” is third-party international organisation that works with UK governments, NGOs and other institutions, to help them support LGBTQ+ people;

Information we collect

"Personal information" is any information that can be used to identify you or that we can link to you. It does not include information where the identity of the individual has been fully and effectively removed (i.e. anonymous data).

Personal information that we collect from you directly

The App enables users to submit reports about incidents that they have witnessed. Please do not submit any personal information about third parties in these reports.

We collect, process, and use some personal information when you download and use the App. The information we collect includes;

  • Your name; and
  • Your email address,
  • if you choose to create a profile or if you provide these details in the Report feature of the App, to be contacted for support.
  • Personal information that you include as part of the reports you provide to us, including details of the incident that you are choosing to report and any other personal details that you choose to provide. This may also include ‘special category data’, which is a type of personal information that is considered more sensitive under data protection legislation (e.g., information relating to sexual orientation race, religion, political affiliation and health).
  • Contact information, if you request support when providing this information toward the end of the report. This information will be processed in order to contact you.

The App will also keep the unidentifiable and ‘multiple-choice’ data of your report (in other words, the parts of your report (and the survey that you complete when providing the report) that cannot be used to identify you) for statistical purposes. This data will be anonymised: it will not be linked to your profile if you have created one, nor to any data that can identify you.

This unidentifiable and ‘multiple-choice’ data is made available to Stonewall and Vodafone Foundation so that they can use it for statistical purposes.

We monitor the performance and usage of the application to improve the user experience. We do not track individuals or collect any personal data. You can see details about our Performance Analytics below.

How we use the information collected

We collect your personal information for the following purposes:

  • Name and Email address – if you would like to set up a profile with us, we will collect your name and email address to set up and maintain your profile. We may also use your email address to contact you if there are any issues with your profile that need your attention.
  • Information provided in your report - Your personal details, including contact details (if you decide to share any) and the detailed information in your report will only be processed for the purposes of providing you with the support that you have requested (if any).
  • Statistical and multiple choice information – As noted above, we store statistical and multiple choice information that you provide as part of the survey that you complete when you make a report. We anonymise this statistical information by stripping it from your user profile (if you have one) and the rest of your report so that it can no longer be used to identify you. This anonymised information is made available to Stonewall and Vodafone Foundation, which will use it for statistical and research purposes, including to further their aims of fighting for the rights of LGBTQ+ people and collaborate with other organisations to carry out research on LGBTQ+ issues. You can find out more about Stonewall and its work on its website here.

We must have a reason under the law in order to collect your personal information (this reason is sometimes known as a ‘legal basis’). There are different legal bases that we rely on to use your personal information provided via the App:

  • Consent you provide – If you decide to share any personal details when filling out the Report, you will be asked to give explicit consent for Galop to access and use your personal information (including any ‘special category data’ that you provide) in order to review the incident and provide you with support if you have requested it. Consent may be withdrawn at any time by contacting Galop at info@galop.org.uk.

  • Performance of a contract – The use of your personal information may be necessary to allow you to use the service provided by the App, including so that you can access the App, and for the purposes of providing you with the support that you have requested. We rely on this lawful basis in order to collect and store your name and email address to create a profile with us, since we need this information in order to create and manage that profile.

  • Legitimate interests – We may use your personal information where this is necessary for our legitimate interests, provided that those interests are not overridden by your own, or by your fundamental rights and freedoms. We process the following personal information on the basis of our legitimate interests:
    • Any of the information that you provide as part of the survey that you complete when you make a report that cannot be used to identify you. We strip this information from the survey so that it is no longer linked to your profile or contact details (in other words, we anonymise it) so that we can use this for statistical purposes and make the anonymized data available to Stonewall and Vodafone. It is in our legitimate interests to anonymise this data and then use it to further one of our missions by using technology to support LGBTQ+ communities.
  • When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected, data is pseudonymized (hidden) whenever and wherever possible, and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

What rights do you have

You have certain rights regarding your personal information, including. the following:

The right to access – You have the right to request copies of your personal data. In very limited circumstances, we may charge you a small fee for this service, based on the administrative costs of complying with the request, e.g. if the request is excessive; or if you request further copies of your data following your initial request.

In relation to the data you provide via any reports you make on the Zoteria App:

  • You can stop the process of reporting at any time prior to submission and your information will not be submitted or stored on our systems.

The right to access – You have the right to request copies of your personal data. In very limited circumstances, we may charge you a small fee for this service, based on the administrative costs of complying with the request, e.g. if the request is excessive; or if you request further copies of your data following your initial request.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you under certain conditions.

Where we rely on your consent to process your personal information, you also have the right to withdraw your consent at any time.

If you make a request, we have one month to respond to you. Galop will be your contact point in relation to the use of your personal information as part of the Zoteria App, so in order to make a request or otherwise exercise your rights, please contact us at info@galop.org.uk.

If you are unhappy about how we have managed your personal data, you can contact the Information Commissioner’s Office (ICO). Their website www.ico.org.uk has details on how to contact the ICO.

How long we keep your data

Creating a user profile is optional to use Zoteria. If you decide to create a profile, we will store your login details in Zoteria’s system, and only Vodafone will have access to this database. This data will be held on the system for as long as you are active on the App, i.e. until you either delete your profile, or you have been inactive on the App for 12 months period of time (whichever is later).

In relation to the data you provide via any reports you make on the Zoteria App:

  • You can stop the process of reporting at any time prior to submission and your information will not be submitted or stored on our systems.
  • The personal data and open text fields from your hate crime report will be removed from the App system 30 days after it has been submitted, but it may be stored longer by Galop if Galop needs the data in order to support you (where you have requested support).
How we share information

Your personal details (if you decide to share any) and the detailed information that you provide in your report will only be processed for the purposes of providing you with the support that you have requested.

As noted above, we anonymise statistical information from the App by stripping it from your user profile (if you have one) and the rest of your report so that it can no longer be used to identify you. We provide this anonymised information to Stonewall.

Stonewall will not have access to names, email addresses, or any other information that can be used to identify individuals.

  • Statistical unidentifiable information will be used by Stonewall and Vodafone for reporting and awareness purposes, and to aid our advocacy work aimed at improving hate crime laws and policies (e.g. in formats such as, ‘52% of people who reported a hate crime in the UK said the incident happened in the evening’).

We may also share your personal information with the following third parties:

  • with contractors, suppliers, or other third parties that provide services on our behalf (such as app or website host providers);
  • as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
  • pursuant to a subpoena, court order, or other legal process or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or the rights or safety of third parties;
  • with our professional advisors, lawyers, accountants and auditors; or
  • with your consent or as otherwise disclosed at the time of data collection, or sharing.
International transfers

We may need to transfer your information to service providers in countries outside the United Kingdom. We will only transfer your information where we have taken steps to ensure that your personal information is protected in accordance with appropriate safeguards, such as the UK International Data Transfer Agreement entered between us and our service providers, or where the Secretary of State has permitted the free flow of data to the relevant jurisdiction.

How we protect your data

We take technical and organisational security measures as required by law and by industry standards to protect your personal data from unauthorised access, use or disclosure.

We take steps to ensure that we only use your personal information as described in this privacy notice and to honour the permission choices that you have made.

We only partner with service providers who contract to provide the same level of information security.

While we seek to use appropriate organisational, technical and administrative measures to protect personal information within our organisation, unfortunately no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact details” section below.

Other websites

The App contains links to external websites. Please note that when you click on these links, you are entering a website for which we have no responsibility (even if you access the website via a link on our App), and which may have a different privacy policy or notice. We encourage you to be aware of other third-party websites and their privacy notices and/or policies.

Changes to this privacy notice

We may revise this Privacy Notice from time to time. The most current version of the notice will govern our processing of your information and can be found in “Privacy Notice” on the App. We will also use reasonable efforts to inform you of any significant changes by email where appropriate.

Contact details

Galop is your contact point in relation to the use of your personal information as part of the Zoteria App. If you have any problems or general requests in relation to your personal data or this Privacy Notice, you can contact us directly through our email address info@galop.org.uk.



Performance Analytics tracking

We use an app SDK to collect performance data from your app and allows us to monitor the performance of the app and how it can be improved, to fix performance issues and improve the experience of the app.

We won’t be able to link the information we collect back to you. All information captured through this monitoring mechanism is aggregated and anonymous, and we don’t capture any personal data.

We do not share this information with third parties.

The Zoteria App uses the following Performance Analytics tracking SDK:

What it’s called

What it’s used for

Type 

Duration

First party

SMAPI

We use SMAPI, a Vodafone tool to measure how users interact with the app, helping us understand the performance of the app.

2. Performance

12 months

Third party

None

None 

None

None

Controlling Performance Analytics tracking

You can manage your Performance Analytics preferences by accessing the settings page, by choosing to enable or disable this tracking.

Effective Date: September, 2022