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PRIVACY & COOKIES POLICY

Last Updated: 11 December 2024

INTRODUCTION

Welcome to Gango Group’s Privacy & Cookies Policy. Gango Group (Company Number: 15267354) respects your privacy and is committed to protecting your personal data in accordance with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy describes how we collect, use, process, and safeguard your personal data when you interact with us, including through our website and our proprietary machines. It also details your rights and how you can exercise them.

If you have any questions, please contact us at sales@gangobar.com.

CONTENTS

  1. Important Information and Who We Are
  2. The Data We Collect About You
  3. How Your Personal Data Is Collected
  4. How We Use Your Personal Data
  5. Disclosures of Your Personal Data
  6. International Transfers
  7. Data Security
  8. Data Retention
  9. Your Legal Rights
  10. Data Collected by Our Machines
  • Non-Identifiable Data
  • Age Estimation
  • Purposes
  • Local Processing & Encryption
  • Retention
  1. Cookies and How We Use Them
  2. Governance and Breach Notification
  3. Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Controller: Gango Group is the data controller responsible for your personal data.

Data Protection Manager (DPM):
Name: Patrick Songore (Managing Director)
Email: sales@gangobar.com

Updates to this Notice: This version is dated 11 December 2024. We may update this notice from time to time, and any changes will be posted on our website.

Third-Party Links: Our website may contain links to third-party sites. We are not responsible for their privacy practices. We encourage you to read the privacy notices of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store, and transfer different types of personal data, including:

  • Identity Data: Name, date of birth, title, and similar identifiers.
  • Contact Data: Email address, telephone numbers.
  • Technical Data: IP address, browser type, time zone settings, operating system, and other technology on devices you use to access our website.
  • Profile Data: Interests, preferences, feedback, and survey responses.
  • Usage Data: Information about how you use our services and website.
  • Marketing Data: Your marketing preferences and communication preferences (only if you opt in).
  • Visit Data: Traffic data, location data, weblogs, and other communications data when you visit our site.

We also collect Aggregated Data (such as statistical or demographic data). Aggregated Data does not reveal your identity. If we link Aggregated Data with your personal data so that it can identify you, we will treat it as personal data.

We do not collect any information about criminal convictions and offences.

3. HOW YOUR PERSONAL DATA IS COLLECTED

  • Direct Interactions: You provide data by corresponding with us via email, phone, or forms on our website.
  • Indirect Interactions: We may receive personal data about you from publicly available sources, social media platforms, or analytics providers.
  • Automated Technologies: As you interact with our website, we may collect Technical and Usage Data using cookies, server logs, and similar technologies.

4. HOW WE USE YOUR PERSONAL DATA

We use personal data only when the law allows, commonly for:

  • Service Fulfillment: To perform contracts we have with you or to take steps at your request before entering a contract.
  • Communication: To notify you about changes to our services or policies.
  • Improvement: To ensure our content is presented effectively and to understand customer needs.
  • Compliance: To meet legal or regulatory obligations.

Legitimate Interests: We may process your data for our legitimate business interests, provided those interests are not overridden by your rights.

If we have obtained your consent for certain processing (e.g., marketing communications), you may withdraw it at any time by contacting sales@gangobar.com.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may need to share your personal data with:

  • Service Providers: Who provide IT, system administration, or operational services.
  • Regulators and Authorities: When required by law.

All third parties are required to respect your personal data and treat it lawfully and securely.

6. INTERNATIONAL TRANSFERS

Some third-party providers may be located outside the UK/EEA. In such cases, we ensure that appropriate safeguards (such as Standard Contractual Clauses) are in place to protect your data.

7. DATA SECURITY

We use robust security measures to prevent unauthorized access, alteration, disclosure, or loss of your personal data. Access is restricted to those with a business need who are subject to confidentiality obligations.

8. DATA RETENTION

We retain your data only as long as necessary for the purposes outlined in this notice or as required by law. Factors considered include the nature and sensitivity of the data, potential risk of harm, and applicable legal obligations.

9. YOUR LEGAL RIGHTS

You have rights under data protection law, including to:

  • Access your personal data.
  • Request correction or erasure.
  • Object to or restrict processing.
  • Request the transfer of your personal data.
  • Withdraw consent at any time if processing is based on consent.

For details on these rights, please see the ICO guidance (www.ico.org.uk). To exercise these rights, contact us at sales@gangobar.com.

10. DATA COLLECTED BY OUR MACHINES

Non-Identifiable Data

Our machines collect and process certain categories of data related to user interactions. All such information is converted into non-identifiable numeric or vectorized values, without any reference or link to an individual’s identity. Each session may be assigned a temporary tracking ID that is valid only for that specific interaction, and this ID cannot be combined with any other data to identify a person. As a result, these datasets do not constitute personal data and are not subject to the requirements of the GDPR.

Age Estimation

We partner with YOTI for age estimation. YOTI provides a numerical age assessment without retaining or returning any personally identifiable images or data.

Purposes

  • Compliance & Safety: To verify compliance requirements and support secure operations on-site.
  • Service Improvement: To retrain algorithms and improve machine performance for a better user experience.

Local Processing & Encryption

All data is processed locally on the machine. Data is encrypted in transit and at rest to prevent unauthorized access. Since the data is numeric, vectorized, and non-identifiable, it cannot be used to recognize or trace back to any individual.

Retention

Data on the machine is retained for no longer than 72 hours. After this period, it is automatically deleted or permanently anonymized so that it cannot be associated with any individual.

11. COOKIES AND HOW WE USE THEM

Cookies are small data files stored on your device. They help us:

  • Enhance website functionality.
  • Understand user behavior to improve site performance.

Types of Cookies Used:

  • Strictly Necessary Cookies: Required for basic site operation.
  • Performance Cookies: Collect anonymous data to improve site efficiency.

You can manage or disable cookies in your browser settings. Doing so may affect website functionality.

12. GOVERNANCE AND BREACH NOTIFICATION

Internal Audits:
We periodically review and audit our data collection and processing activities, including those related to our machines, to ensure ongoing compliance with applicable laws, standards, and internal policies.

Breach Notification:
In the unlikely event of a personal data breach, we will notify the relevant regulators and affected individuals promptly as required by law. Notifications will detail the nature of the breach, the data involved, and the measures taken to mitigate potential harm.

13. GLOSSARY

  • Aggregated Data: Data combined from many individuals so that it cannot identify any individual.
  • Legitimate Interest: A business interest that does not override an individual’s fundamental rights and freedoms.
  • UK GDPR: The UK General Data Protection Regulation, governing the handling of personal data in the UK.

Contact Us:
Email: sales@gangobar.com
Address: 19 Jacobs Piece, Fairford, GL7 4FH

© Gango Group 2024. All Rights Reserved.