Groovin Privacy Policy

1. Introduction

This Privacy Policy is provided by Cultura Labs Ltd, a company registered in England and Wales under company number 17159433 with registered office 66 Paul Street, London, England, EC2A 4NA (we, our or us) for use of our services including our app, website and associated services (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2. What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section "Who we share your personal data with" below.

3. Personal data we collect about you

The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:

Category of data In more detail
Identity and account data you input into the Services
  • Registration is mandatory in order to use the Services
  • Your name and email address
  • Your account details, such as username and password
  • Your date of birth for age verification/age-appropriate access and experience
  • Password and login credentials
  • Account type and account status
Data collected when you use specific functions in the Services including profile and preference data

Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were) including:

  • preferred dance styles
  • dance experience level
  • how you heard about us
  • booking history
  • profile information, photos or biographies that you choose to upload
Booking and transaction data
  • details of Bookings you make, receive, cancel, reschedule or attend, including check-in and attendance records
  • Event Listing details
  • amounts paid, refunds, credits, gift cards or discounts applied
  • payment status and transaction reference information, including the identifier of the Organiser's Stripe account that received your payment and the customer record created for you in it (we never receive or store your full card number)
  • if you pay an Organiser in person through the Services without an account, the name, email address and phone number the Organiser enters to record your purchase and send you a confirmation and check-in details
Data you provide through bookings, messages, enquiries or participation-related interactions
  • booking details and attendance information
  • communications between you and Organisers or between you and us through the Services
  • information you choose to provide in connection with participation in an Event Listing, which may include health, fitness, injury, accessibility or other participation-related information where relevant to safe participation
Organiser data
  • organiser name and trading name
  • email address and phone number
  • studio or venue address details
  • Stripe account ID, account and payout status, and fee, invoice and refund information relating to payments made to your Stripe account
  • your Instagram handle and other public links you choose to display
  • information you provide about qualifications, licences, insurance, safeguarding or compliance
Communications and support data
  • messages sent through the Platform
  • communications with us, including support enquiries, complaints, dispute information and feedback
  • reviews, ratings, testimonials and other content you submit
Other data the Services collects automatically when you use it
  • Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use
  • IP address
  • device type, operating system, browser type, app version and device identifiers
  • log data, approximate location inferred from IP address, time zone setting and usage analytics
  • crash reports from the app, which include your user ID, app version, device model and operating system, and the screens you visited in the app leading up to the crash
  • the token that identifies your device for push notifications
  • referral codes and campaign parameters from links you used to install or open the app
  • information about how you use the Services, including pages viewed, features used and interactions with Event Listings
Location data

Where you allow the Services to use your device's location, we use your location at that moment to work out which area's classes, socials and events to show you and to sort them by how close they are to you. Your location is sent to our servers to match it to an area, and we do not keep a history of where you have been. Location access is optional: you can decline or withdraw it in your device or browser settings and choose an area manually instead.

If you are an Organiser taking an in-person card payment, the app asks for your precise location at the time of the payment because Stripe requires the location of an in-person card payment. It is used only while you take the payment and is shared with Stripe for that purpose.

Marketing and preference data
  • your marketing preferences
  • whether you have opened or clicked a marketing communication we have sent, where permitted by law
Data collected when you make an enquiry with us Your email address and, where you provide them, your name, organisation, dance styles, the topic of your enquiry and the message you send us through our website contact and register-interest forms or the in-app support form.

If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you. Location access is not required: if you do not allow it, you can choose an area manually and the Services will still work.

We do not generally require special category personal data, such as health data, for ordinary account creation or everyday use of the Services. However, in some cases, you may choose to provide participation-related information through the Services, including in messages, booking-related communications or responses to Organiser requests, and this may include health information where relevant to safe participation.

We collect and use this personal data for the purposes described in the section "How and why we use your personal data" below.

4. Sensitive Data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person's sex life; and data concerning a person's sexual orientation.

We do not generally require special category personal data for standard account registration or ordinary use of the Services.

However, because the Services connect Customers with Organisers for dance classes, workshops and events, there may be circumstances in which:

  • an Organiser requests health, fitness, injury, accessibility or other participation-related information from a Customer where relevant to safe participation in an Event Listing; or
  • a user chooses to provide health or other special category personal data through the Services, including in messages, enquiries, booking communications or other user-generated content.

Where we process special category personal data, we will do so only where and to the extent permitted by applicable law, including where we have identified an appropriate lawful basis under Article 6 UK GDPR and, where required, an applicable condition under Article 9 UK GDPR.

In general:

  • the Platform does not require health data for ordinary account creation;
  • Organisers are responsible for deciding what health or participation-related information they require for the delivery, safety and suitability of their Event Listings; and
  • where health information is provided through the Services, we may process it on an incidental and limited basis as necessary to operate the Services, transmit and store communications, support bookings, address safety or safeguarding issues, handle complaints or incidents, comply with legal obligations, and enforce our terms.

Organisers are independently responsible for their own lawful processing of any health declarations or other special category personal data they require for service delivery, safety or compliance purposes.

5. How your personal data is collected

We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

Some information comes from your device, only where you have given the relevant permission and only for the purpose you granted it: your location (see "Location data" above), your camera (to scan check-in QR codes), your photo library (to choose a profile or organisation image, or to save a QR code) and your calendar (to add a Booking to it; we do not read your existing calendar entries). You can withdraw any of these permissions at any time in your device settings.

We also receive personal data from other people. If you pay an Organiser in person through the Services, the Organiser enters your details to record the purchase. If you sign in with Apple or Google, that provider sends us your name and email address (or, with Apple, a private relay address if you choose to hide your email). When you pay, Stripe sends us confirmation of the payment, its status and any refund or dispute, but not your full card details.

We do not use cookies or similar technologies for advertising or tracking. Our website and apps store a small amount of information on your device that is strictly necessary to provide the Services, such as your sign-in session and the area you have chosen to browse. If we ever decide to use cookies or similar technologies for any other purpose, we will tell you in advance through the Services and publish a cookies policy explaining what they are used for.

6. How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract with you or to take steps at your request before entering into a contract, or
  • for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see "How to contact us" below).

We may also process participation-related information, including health information you choose to provide through the Services, where this is necessary to operate the Services, transmit communications, support bookings, deal with safety, safeguarding, complaints or incidents, protect users and the Platform, comply with legal obligations, or enforce our terms. Where such information is special category personal data, we will only process it where we have identified an appropriate lawful basis and special category condition under applicable data protection law.

The table below explains what we use your personal data for and why.

What we use your personal data for Our reasons
Create and manage your account with us To perform our contract with you or to take steps at your request before entering into a contract
Enabling Organisers to create, publish, manage and fulfil Event Listings and receive payouts To perform our contract with you
Facilitating Bookings and sharing relevant booking, contact, attendance and participation-related information with the relevant Organiser so that the Organiser can deliver the relevant Event Listing. To perform our contract with you or take steps at your request before entering into a contract; to comply with legal obligations; and, where applicable, for our legitimate interests in operating the Platform, enabling Bookings to be administered and fulfilled, ensuring Organisers have the information reasonably necessary to deliver Event Listings safely and effectively, handling complaints, incidents and disputes, and preventing fraud, misuse and booking-related abuse.
Providing services and/or the functionalities of the Services to you

Depending on the circumstances:

  • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
Processing participation-related information, including health information you choose to provide through the Services, for booking administration, communications, safety, safeguarding, complaints, incidents, platform support, legal compliance and enforcement of our terms.

Depending on the circumstances:

  • to perform our contract with you or take steps at your request before entering into a contract;
  • to comply with our legal and regulatory obligations;
  • for our legitimate interests, including operating the Platform, supporting bookings, protecting users, handling complaints and incidents, and preventing misuse; and
  • where the information is special category personal data, only where we have identified an additional lawful condition under applicable data protection law.
Using account, usage and preference data to personalise class recommendations and platform content For our legitimate interests in personalising the user experience, helping users discover more relevant classes, workshops and events, reducing irrelevant results, improving engagement with the Services, and improving the performance and usability of the Platform
Using your device's location, where you allow it, to show you classes, socials and events in your area and sort them by distance Your consent, given through the location permission on your device or browser, which you can withdraw at any time in your settings; and our legitimate interests in showing you relevant results. If you do not allow location access you can choose an area manually.
Facilitating payments you make directly to Organisers through Stripe, including creating a customer record for you in the Organiser's Stripe account, collecting our fees from those payments, and administering refunds, chargebacks, disputes, fraud checks, Organiser payouts and invoices, and transaction records

Depending on the circumstances:

  • to perform our contract with you;
  • legal obligation; or
  • legitimate interests in administering payments and payouts, reconciling transactions, preventing fraud and unauthorised transactions, handling chargebacks and payment disputes, maintaining accurate financial records, and protecting the Platform, users and payment flows from misuse and loss.
Recording in-person purchases and check-ins, including details entered by an Organiser about a customer who does not hold an account, and sending that customer a confirmation and check-in details To take steps at the customer's request before entering into a contract and to perform it; and our legitimate interests in keeping accurate records of sales and attendance for Organisers, handling refunds and disputes, and preventing fraud.
Providing customer support and responding to enquiries, complaints, disputes and safeguarding concerns Performance of a contract; legal obligation; legitimate interests in providing user and organiser support, resolving enquiries, investigating complaints and disputes, dealing with safeguarding and safety concerns, maintaining service standards, and protecting the Platform, our users and our business from harm.
Operating, maintaining, securing and improving the Services, including troubleshooting, crash reporting, testing, analytics, rate limiting and service optimisation Legitimate interests in operating the Platform effectively, maintaining service availability and reliability, diagnosing and fixing technical issues, testing new features, monitoring performance, improving platform functionality, and ensuring the Services remain secure, stable and fit for purpose.
Monitoring use of the Services, enforcing our terms, preventing fraud, misuse, unsafe conduct and other prohibited behaviour, including automated screening of images and text you submit for unsafe or inappropriate content Legitimate interests in monitoring misuse of the Platform, detecting and preventing fraud, unsafe conduct, policy breaches and prohibited behaviour, enforcing our terms, protecting users and Organisers, preserving trust in the Platform, and reducing legal, operational and reputational risk; legal obligation
Communicating with you about your account, Bookings, Event Listings, updates to our Services, terms or policies, and other non-marketing service messages Performance of a contract; legal obligation; legitimate interests in administering accounts and Bookings, keeping users informed about important operational, safety, policy and service changes, maintaining service continuity, and ensuring users receive timely information relevant to their use of the Platform
Sending marketing communications about our own products or services, including push notifications about deals, special events and featured classes Consent, or where permitted by law, our legitimate interests and PECR soft opt-in rules. You can switch marketing push notifications off in the app's notification settings and unsubscribe from marketing emails at any time.
To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

  • to comply with our legal and regulatory obligations
  • in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices

Depending on the circumstances:

  • to comply with our legal and regulatory obligations
  • where not required by law, for our legitimate interests in administering the Services, keeping users informed about account, booking, policy and service changes, maintaining service continuity, and communicating important operational or safety information relevant to use of the Platform
Protect the security of systems and data To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you, supporting users and Organisers, improving internal processes, training staff, maintaining service quality, troubleshooting issues, handling complaints, managing disputes, and improving the reliability and usability of the Services
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app, understanding how users interact with the Services, monitoring usage trends, analysing performance, planning platform improvements, measuring the effectiveness of features and communications, forecasting demand, and improving the relevance, usability and commercial sustainability of the Platform.
Updating and enhancing user records

Depending on the circumstances:

  • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
  • to comply with our legal and regulatory obligations
  • where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations

Depending on the circumstances:

  • to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
  • to comply with our legal and regulatory obligations
  • where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

  • to comply with our legal and regulatory obligations
  • in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See "Who we share your personal data with" for further information on the steps we will take to protect your personal data where we need to share it with others.

7. Marketing

We intend to send you email marketing to inform you of our services such as promotions. The app can also send you push notifications about deals, special events and featured classes; these are separate from the essential notifications about your Bookings, and you can switch them off at any time in the app's notification settings.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see "Your rights" below.

8. Who we share your personal data with

Our service providers may include Google/Firebase, Microsoft/Azure, Stripe and other providers who assist us with hosting, authentication, payments, analytics, communications and support. In particular:

  • Stripe processes every payment made through the Services and provides the Stripe accounts through which Organisers are paid. When you pay, your card or wallet details go directly to Stripe and we never receive your full card number. Stripe also uses your data for its own purposes, such as fraud prevention and regulatory compliance, as an independent controller under its own privacy policy.
  • Google provides Firebase, which we use to sign you in and to send push notifications, and Firebase Crashlytics, which receives crash reports from the app together with your user ID and the screens you visited before the crash. We also use Google's Maps and Places services to look up and display venue addresses and map images.
  • Microsoft provides the Azure cloud services that host the Services and store your data, the email service we use to send you Booking confirmations and other messages, and the Azure AI Content Safety service that automatically screens images and text submitted to the Services.

Furthermore, we routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers, cloud-based team communication and workspace platforms, payment processors, email marketing platforms, customer relationship management tools, customer support software, logistics and shipping partners, survey and feedback tools, advertising and retargeting networks, analytics providers, professional advisers (such as our accountant), legal and regulatory authorities.

We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may share personal data with the relevant Organiser where reasonably necessary for the administration, fulfilment and safety of a Booking or Event Listing. This may include your name, username or display name, contact details, booking details, attendance and check-in information, payment, refund and dispute information for the Organiser's Event Listings, communications made through the Services, and any participation-related information you choose to provide that is relevant to the relevant Event Listing.

Payments you make through the Services go directly to the Organiser's Stripe account, and the Organiser is the merchant of record for your purchase. This means the Organiser can see your name, email address and the details of your payment (such as the amount, date, card type and the last four digits of your card) in its Stripe account, and Stripe creates a customer record for you in that account so that payments and refunds can be processed. The Organiser is responsible for that information as a controller in its own right, and Stripe's privacy policy applies to Stripe's own use of it. If you pay an Organiser in person through the Services, the Organiser collects your details and enters them into the Services; the Organiser is responsible for collecting them lawfully, and we process them to record the sale, send you a confirmation and provide check-in details.

When we share personal data with an Organiser for those purposes, we and the Organiser will generally act as separate controllers for our own respective processing activities. We process personal data for purposes such as operating the Platform, managing accounts and bookings, payments, customer support, fraud prevention, legal compliance and enforcement of our terms. The Organiser processes personal data for its own purposes such as delivering Event Listings, communicating with participants, managing attendance, assessing suitability, handling safety and safeguarding issues, complying with legal obligations and managing its own customer relationship.

Once personal data has been shared with an Organiser for those purposes, the Organiser is responsible for its own compliance with applicable data protection law in relation to its independent processing of that personal data.

Organisers are not our processors for the purpose of delivering their own classes, workshops, events and related services. In relation to that processing, they act in their own capacity and under their own privacy obligations.

We or the third parties mentioned above may occasionally also need to share your personal data with:

  • external auditors, e.g. in relation to the audit of our accounts and our company; the recipient of the information will be bound by confidentiality obligations
  • professional advisors (such as lawyers and other advisors); the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
  • other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency; usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see "How to contact us" below).

We will not share your personal data with any other third party.

9. How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a "need to know basis" have access to such data.

Records of Bookings, payments, refunds, disputes and Organiser payouts are financial records that we must keep for accounting, tax and legal purposes, so we keep them for up to 6 years after the transaction even if you close your account, anonymising them where we can. The same applies to the details recorded when you pay an Organiser in person without an account. If you ask us to delete your account, we remove or anonymise the personal data in your profile but retain these transaction records for that period.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

10. Transferring your personal data out of the UK

At this point in time, we do transfer your personal data outside of the UK (where service providers or their servers are located outside the UK). We comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on "Changes to this privacy policy" below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an "adequacy regulation") further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, when transferring your personal data from the UK to:

  • The EEA: we rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
  • The United States: we may rely on an applicable adequacy mechanism, including where the relevant recipient is certified under the UK Extension to the EU-U.S. Data Privacy Framework. Google LLC, Microsoft and Stripe state that they comply with the UK Extension to the EU-U.S. Data Privacy Framework.
  • Any country located outside the UK/EEA: we rely on an appropriate safeguard under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

11. Your rights

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Your right What it means
Access to a copy of your personal data The right to be provided with a copy of your personal data.
Correction (also known as rectification) The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data, in certain situations.
Restriction of use The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations.
To object to use

The right to object:

  • at any time to your personal data being used for direct marketing (including profiling)
  • in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by the Services. We do use automated tools to screen images and text submitted to the Services for unsafe or inappropriate content, and to apply the refund rules described in our Terms & Conditions when a Booking is cancelled or changed; if you believe an automated screening decision is wrong, contact us and a member of our team will review it.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see "How to contact us" below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form (available on our website at https://forms.office.com/e/WdQm7TcYgM) or email, call or write to us (see below: "How to contact us"). When contacting us please:

  • provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates

We will respond to requests to exercise your data protection rights without undue delay and normally within one month of receipt. We may extend that period by up to a further two months where your request is particularly complex or where we have received a number of requests from you, in which case we will let you know within the initial one-month period.

12. Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

13. How to complain

Please contact us if you have any queries or concerns about our use of your information (see below "How to contact us"). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

14. Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

15. How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Cultura Labs Ltd
66 Paul Street, London, England, EC2A 4NA
Email: groovin-developer-support@cultura-labs.com