Introduction and summary
At My First Five Years we know that your personal information is important to you. That’s why whenever we process it, we only use what we need to, and we do everything we can to ensure it is appropriately protected.
This notice explains the situations where we may process your personal data and the steps, we take to protect it. In summary:
- Most of the personal information we collect is provided directly by you and is necessary to deliver the service you have requested. We only ask for the information that we absolutely need.
- We do collect some personal information automatically – such as IP addresses, pages viewed on our website and links you’ve clicked on. This is predominantly through the placement of cookies which are explained in detail later.
- If you have given us appropriate permission to do so, we may send you information about products and services we offer.
- If you have given us appropriate permission to do so, we may use images and videos that you provide of your child (and you, if applicable) in online promotion of services we offer.
- If you have given us appropriate permission to do so, we may share your information with businesses that partner with My First Five Years.
- To help you get the most out of our marketing, we may sometimes tailor it to you using your personal information. We will do this by building a profile about you, for example, to understand what services you currently use, or may have a future need for. You can object to this (explained later) and receive non-personalised marketing instead.
- We use selected third parties to provide some of our services (e.g., courier companies to deliver online orders) and will share the minimum personal data necessary with them to do so.
- Like most organisations, we use third parties to support the running of our business (e.g., using an application) and, in certain circumstances, these third parties may have access to your data. This may be from outside of the European Union. Where this is the case, we have appropriate protective measures in place to ensure your information is appropriately protected, Except for tailored marketing (as mentioned above) we do not make any automated decisions - i.e., a decision which does not involve a human providing an opinion - about you in delivering our services.
Updating this notice
How can you contact us?
You can contact us by email at Hi5@mffy.com
What if you need to complain about how we have used your personal information?
You can make a complaint about how we have used your personal information to us by contacting us at Hi5@mffy.com .
You are also entitled to complain to the Data Protection Supervisory Authority – which in the UK is the Information Commissioner's Office (ICO). You can find their contact details at https://ico.org.uk
What are your privacy rights and how can you exercise them?
Under law, you have the following rights:
- Right of Access: you have the right to know how we process your personal information (as explained in this notice) and a right to receive a copy of your personal information.
- Right of Rectification: you can ask us to change or complete any inaccurate or incomplete personal information held about you.
- Right to Object: you have the right to object, in certain circumstances, to us processing your personal information. For example, you can object to us sending you marketing material or using your personal information to create a profile about you.
- Right to Erasure: in certain circumstances, you can ask us to delete your personal information. For example, where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Right of Portability: you have the right to ask us to send a copy of certain elements of your personal information (predominantly information you have shared directly with us) to another company.
- Right to Restrict: you can ask us to restrict the personal information we use about you where you have asked for it to be erased (and the erasure has not taken place, or we were unable to erase the data when we should have) or where you have objected to our use of it.
To exercise the Right of Access, email us at:Hi5@mffy.com
Exercising your rights is free and we will respond to any request as quickly as we can. Under current law, we have up to a calendar month to respond to any request. We will endeavour to meet this. If we can’t, we’ll contact you to explain why we need to extend the time limit along with the reason why.
What personal information do we collect and how is it used?
What we collect and how we use it depends on how you interact with us and the specific services you have requested. This is outlined below.
- To fulfil your needs - we capture your name, e-mail, we process your payment card details to provide the services you have requested. We do not store these details. For any repeat orders of products or services made by you via our app are stored by your device provider (Apple) - you can find out more here - https://support.apple.com/en-gb/billing
- If you interact with us online (for example, when you use our website, digital services, or post comments on our Facebook page) we will indirectly collect information about you. We collect certain usage information when you utilise our website such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our website and the products and services we offer, and other usage information collected from cookies and other tracking technologies. For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate our website. We collect this information for our own legitimate business interests to enable us to understand how digital services are used and how we can improve them.
- If you have an account with us online, we may collect your IP address as part of the login process. This is a security feature to protect your account.
- If you choose to share photos or videos for our use in online promotion, we will use those photos or videos in accordance with the consent you grant. You can always withdraw consent you have granted by contacting us at [Hi5@mffy.com]. Please allow us a reasonable time after receiving your notice to cease all use of your materials.
- If you call us, we may record or monitor the call. We do this for training, to ensure and improve quality of service delivery, to ensure safety of our colleagues and customers, and to resolve queries or issues. Doing so is a legal obligation. Where we analyse calls to improve our service, we do so as a legitimate business interest.
- If you call us, we may record the conversation for training and monitoring purposes. We do this for our own legitimate interests, primarily to enable us to improve our customer experience.
- If you visit one of our offices as a guest (contractors, suppliers, guests, other non-customer individuals) on a one-time/ad-hoc basis or as part of a long-term agreement, your first name, surname, organisation/company name and vehicle registration will need to be recorded in our visitor system the purposes of site security, health, and safety.
What personal information do we collect in our app and how is it used?
- Your name (the parent/guardian), We ask for your name to provide you with a personalised setting.
- Your email is used as your username to log in to the app.
- Your baby’s date of birth / due date, we ask for this so we can estimate where your child could be in their development stage.
- Your baby’s name and gender, this is so you can keep track of multiple profiles and for us to provide a personalised service.
- Your baby’s photo, users may upload an image of their children(s) to their profile from their device. In case the user has previously granted access to any other 3rd party storage provider (such as Apple iCloud or Google drive), the child's photo may be uploaded from there as well. My First Five Years does not have access to this information and does not process this information.
- Images / Videos scrapbook - My First Five Years in-app images / videos are stored on Amazon Web Services (AWS)
Amazon Web Service: https://aws.amazon.com/service-terms/
- Backup & Restore: Users can backup and restore their profiles via their Apple account:
Who do we share your personal information with?
In the previous section we described particular instances where we share your personal information with others. There are also other third parties that we use to deliver services to you. In this section, we have summarised the categories of third parties who we may share your data with.
- Postal services and couriers – for typical business purposes, to deliver an order to your address.
- Third party content processors – for example, to deliver our advice and information about our products and services to you (e.g., an email delivery service), or to collect reviews from our users.
- Law Enforcement Agencies (LEA) – where we are required to do so by law, we will release personal data to LEA’s (e.g., the police). This will most likely be for the detection or prevention of crime, or to exercise or defend a legal claim.
Where do we process your personal data from?
We may need to transfer your information outside the UK to service providers, agents, and subcontractors in countries where data protection laws may not provide the same level of protection as those in the United Kingdom, such as the USA. Where this happens, we agree specific assurances in our contracts with those providers to ensure there are appropriate controls in place to protect your data.
How long will we keep your personal information?
We will retain your personal information for as long as we are legally or contractually required to do so, or for a period which is justifiable to meet our business needs. The exact retention period varies depending on the type of information and purpose for use, if you require any further information on retention periods, please contact us at Hi5@mffy.com
Marketing and profiling
If you have given your consent, we will contact you about the products and services we offer.
We will send these communications to you by either email or SMS or both, depending on what you signed up to. Every marketing communication we send will include instructions on how to opt-out. At any time, you can change your marketing preferences by emailing: Hi5@mffy.com
The marketing we send to you may be tailored to make it more relevant. This is done by analysing the data we hold on you (e.g. services previously used, age, address) to create a profile. If you want to receive marketing from us, but do not want this to be tailored then you can object to the profiling as described under "What are your privacy rights and how can you exercise them?". Alternatively, unsubscribing from marketing will also cease the profiling activity we conduct.
If you have consented to marketing, you may also receive adverts from us online and on social media. We send pseudonymised data to companies such as:
- Facebook / Instagram
- Google / Bing
This means we send the data in a way that only the intended end user (e.g., Facebook, Google) can understand. We may also use your data to build profiles and/or custom audiences. When we do this, we anonymise your data. This means we send your data to platforms (e.g., Facebook, Google) in a way that means you cannot be identified by it.
We only work with companies who take privacy as seriously as we do.
Keeping you up to date
To deliver our services to you, it is necessary to contact you using the contact mechanisms you have given us. This may be by issuing an email, SMS or by phone. These communications are necessary, and we will use the relevant communication method to ensure we provide you with the information you need. You can inform us of communication preferences (e.g., email rather than phone call) and we will endeavour to follow your preferred mechanism. However, we reserve the right to use any contact information we have to deliver necessary information to you.