Privacy policy

1. Who we are

The InCheshire App ("the App") is provided by Cheshire West and Chester Council ("we", "us"). We are the data controller for the personal information collected through the App.

• Address: Cheshire West and Chester Council, The Portal, Wellington Road, Ellesmere Port, CH65 0BA
• ICO registration number: Z1542890

Our Data Protection Officer's contact details are in section 15.

The App is built and operated on our behalf by Vicinity Trading Limited, Commer House, Tadcaster Enterprise Park, Station Road, Tadcaster, West Yorkshire, LS24 9JF. Vicinity acts as our data processor: they handle your data only on our written instructions and cannot use it for their own purposes.

2. The InCheshire App Partnership

The App is guided by a working group of local organisations — including business improvement districts, business groups, landowners, community safety partners and other named stakeholders.

Some of these organisations have access to a dashboard that shows App activity, and in limited cases this includes personal information. They can only use that information to help run the App on our behalf. They are bound by the group's Terms of Reference and a written data sharing/processing agreement, which means they cannot contact you directly, market to you, sell your details, or use your information for their own purposes. All communication with you comes from us.

3. What information we collect

We do not knowingly collect special category data (such as health, ethnicity or religion) through the App.

4. Why we use your information, and our legal basis

You do not have to give us your information, but without an account you will not be able to use features such as loyalty rewards, saved offers or competitions.

5. Marketing and notifications

If you opt in, we may send you push notifications or emails about local news, events, offers and promotions. Some of these will be on behalf of local businesses and partner organisations in the InCheshire App Partnership — but the message comes from us, and we do not pass your contact details to them in order to send it.

You can change your marketing preferences at any time in the App's settings, by using the unsubscribe link in any email, or by turning off notifications in your device settings. Turning off marketing will not stop essential service messages (for example, confirming an account change).

6. Location data

Location is only collected if you allow it in your device settings. We use it to show you nearby businesses, offers, events and trails, and to enable check-ins and location-based rewards.

We do not track your location in the background. We do not sell location data, and we do not share it with third parties for advertising. You can switch location access off at any time in your device settings without losing access to the rest of the App.

7. Competitions, prize draws and offers

Sometimes a competition, prize draw or offer is run by or with a local business. If your details need to be passed to that business — for example so they can contact a winner or honour a prize — we will tell you clearly at the point of entry and ask you to agree. If you do not agree, you do not have to enter.

Where we do share your details in this way, that business becomes responsible for your data from that point and will use it under their own privacy policy.

8. Who else sees your information

We are careful about who we share your information with. There are three different situations, and they work differently.

8a. Suppliers working on our instructions

These organisations handle your information only to do a job for us. They cannot use it for their own purposes, and they are bound by a written contract that requires them to keep it secure and delete or return it when the work ends.

• Vicinity Trading Limited — builds and runs the App for us. To do this, Vicinity uses:
  • Microsoft Azure and MongoDB Atlas — secure hosting and databases
  • Intercom — handling support requests only
  • Apple and Google — app distribution, push notifications and crash reporting
• Mailchimp — sending emails and newsletters
• Marketing and creative agencies — designing and delivering campaigns on our behalf

We use a small number of other suppliers in these categories from time to time. A current list of the suppliers who handle personal data for the App is available at www.incheshire.app/partners, and you can also request it using the contact details in section 15.

8b. Partner organisations in the InCheshire App Partnership

Named partners with dashboard access are listed at www.incheshire.app/partners. They can view App activity, including limited personal information, but only to help us run the App. As set out in section 2, they cannot contact you directly, market to you, pass your details on, or use your information for their own purposes. This is a condition of their access and is set out in a written agreement with us.

8c. Businesses and organisations acting for themselves

Occasionally your details are passed to another organisation that then becomes responsible for them in its own right — for example a business running a competition you have entered, as set out in section 7. This only happens where you have specifically agreed to it, and we will tell you who the organisation is at the time. From that point, their own privacy policy applies.

Other disclosures

We may also be required to disclose information by law, to prevent or detect crime, or to protect someone's safety.

We do not sell your personal information, and we do not share it with third parties for their own advertising.

9. Where your information is stored

Your information is stored on secure servers in the UK and the European Economic Area.

Some of our suppliers process data in the United States. Where that happens, the transfer is protected by recognised safeguards — the UK Extension to the EU-US Data Privacy Framework or the International Data Transfer Addendum to the EU Standard Contractual Clauses. You can ask us for a copy of these safeguards using the contact details in section 15.

10. How long we keep your information

• Account information — while your account is active, and for up to 3 years after you last use the App
• Loyalty and transaction history — 3 years, then deleted or anonymised
• Competition entries — 12 months after the competition closes
• Marketing consent records — for as long as you are subscribed, plus 2 years as proof of consent
• Support messages — 2 years
• Anonymised usage statistics — kept indefinitely; these cannot identify you

You can request that we delete your data through the App, as part of closing your account.

11. Your rights

Under UK data protection law you have the right to:

• Access the personal data we hold about you
• Correct information that is wrong or incomplete
• Delete your information ("right to erasure")
• Restrict how we use your information
• Object to processing we carry out under public task or legitimate interests
• Portability — receive your data in a reusable format, or have it sent to another provider
• Withdraw consent at any time, including for marketing and location

To exercise any of these rights, contact us using the details in section 15. We will respond within one month.

If you are unhappy with how we have handled your information, you can complain to the Information Commissioner's Office: ico.org.uk/make-a-complaint or 0303 123 1113. We would appreciate the chance to put things right first.

12. Children

The App is intended for people aged 13 and over. If you are under 13, please ask a parent or guardian before creating an account. If we become aware that we hold data for a child under 13 without appropriate consent, we will delete it.

13. Links to other websites and businesses

The App contains links to business websites, booking pages and social media. We do not control these and are not responsible for how they handle your information. We recommend reading their privacy policy before giving them your details.

14. Changes to this policy

We may update this policy from time to time. If we make significant changes we will let you know through the App or by email before they take effect. The version number and date at the top show when it was last updated.

15. Contact us

For all enquiries, please contact hello@incheshire.app and our team would be happy to help.

For data protection matters, including any of the rights set out in section 11, we would be happy to help in the first instance at the same address. If you would prefer to raise the matter directly, or you are not satisfied with our response, you can contact the Council's Data Protection Officer:

• Email: dpo@cheshirewestandchester.gov.uk
• Post: Data Protection Officer, Cheshire West and Chester Council, The Portal, Wellington Road, Ellesmere Port, CH65 0BA