Privacy Policy

Updated 7 March 2024

Introduction

This privacy policy (the Policy) relates to your personal data in connection with your use of and access to our social planning and calendar management mobile application ‘Howbout’ (the Howbout App) (available via both the Google Play and the Apple App Store) as well as our website (available at https://howbout.app) and any related website, subdomain or other software application operated by us (all of this together forming the Platform).  

We are committed to protecting your personal data and your right to privacy.  When you use the Platform, you trust us with your information. We take your privacy very seriously. We want to explain in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. 

Changes to the policy or your personal data

We review this Policy regularly and it is your responsibility to check regularly and determinate whether this Policy has changed.  We’ve worked hard to create a Policy that is clear and written in plain English. But if you have any questions, feel we’ve overlooked something or missed an important perspective, we’d love to hear from you. Please get in touch with us by emailing us at [email protected].  In the event we make any significant changes to the Policy we will use our best endeavours to inform you of such changes in advance in writing.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes, for example, when you change your email address.

About us

The Platform is owned and operated by Howbout Ltd (trading as Howbout), a company registered in England and Wales with company number 11962821 whose registered office is situated at Shoreditch Exchange, Senna Building, Gorsuch Place, London, England, E2 8JF (Howbout/we/us/our). Howbout is the controller (also known as a data controller) and is responsible for your personal data.  The term “you” refers to the user wishing to access and/or use the Platform. 

Howbout is a social planning and calendar management app. Users who register an account (a Registered User) can send and receive friend requests to and from other Registered Users. Accepted friend requests result in those Registered Users becoming friends on Howbout (Friends).

Registered Users have the option to share their Howbout calendar (Calendar) or limited Howbout calendar information (limited to the start and end time of events and the attendance status) (Availability) with their Friends. When sharing their Calendar or Availability, Registered Users can also choose to include any or all third party calendars they have chosen to integrate with their Howbout Calendar. Availability is shared by default if Registered Users don’t change this setting. 

Registered Users can create, be invited to, respond to and chat on Howbout events, which includes a ‘plan’, ‘blocked time’, ‘social’ event, ‘personal’ event or ‘idea’ (Howbout Events) with other Registered Users. Registered Users can also create, be added to and chat on Howbout groups (Howbout Groups) with other Registered Users. Registered Users can also directly chat with other Registered Users. 

Registered Users can invite other Registered Users to Howbout Events and add other Registered Users to Howbout Groups through the Platform. They can also send friend requests, invite a non-Howbout user (an External Individual) to Howbout Events and invite an External Individual to Howbout Groups through a link via other communication platforms, for example, by SMS text message. 

How do we use your data?

In Short: We collect personal data that you provide to us including information such as your name and email address, and information about your contacts and calendar data while using our app.

• When you use our Platform we will collect personal data provided by you such as the following:
  • your first and last name, a photograph, email address, and phone number. We only process your personal data via our app if you have given us consent to do so;
  • information about your connections when you become Friends with other Registered Users;
  • location information (if you give us your explicit consent), including your geolocation (latitude and longitude) which we can collect through various means (depending on your device and service), such as GPS and WiFi;
  • information about your contacts which you have in your phone contact directory (if you give us your explicit consent);
  • calendar and event information held with third-party providers such as Google calendar, Microsoft Outlook calendar and Apple calendar (if you give us your explicit consent);
  • photos, video, documents and other digital media information which you upload from your phone’s gallery (if you give us your explicit consent) or take and upload with your phone’s camera (if you give us your explicit consent); and
  • device advertising identifier (if you give us your explicit consent).

• To send you marketing information. Where you have previously expressed an interest in our services (and have not opted-out of marketing) we will use your name and email address to send you updates because it is in our legitimate interests to promote our other products and services we think you might be interested in. 
  • Where you are a Registered User and have opted in via our account registration page to receive updates on our and/ or third party products and services including offers, promotions and new options, we will process your personal data to provide you these updates in line with the preferences you have provided and will only use your personal information in this way with your consent. You can withdraw your consent to marketing at any time by contacting us at [email protected] or, where relevant, by following the unsubscribe link in any marketing communication you receive from us.

• When you contact us either by phone, email, via our 'contact us' page or via social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.

• When you sign up to the Platform through a third-party account or social networking service (such as Apple or Google, each a Social Login, we may extract information from your applicable Social Login account (for example your name, email address, photograph, event and activity information and other personal information that your privacy settings on the Social Login account may permit us to access);

• When you use our website and consent to our use of cookies we will collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our Cookie Policy.

Who do you share my data with?

In Short: We only share information to comply with Legal Obligations, to protect your rights, fulfil our business obligations to you or with your Consent.

• Business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you.
• Promotional events and marketing organisations, we do not sell data for marketing purposes, but may share your data with an event organiser or collaboration brand including where we run workshops with co-presenters and offer a promotion alongside a partner brand. We will always tell you before (usually on the event registration form) and you will be given the chance to opt-out before we do this.
• Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
• Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.

We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Platform. In such circumstances we do not disclose any information which can identify you personally.

Is your data transferred internationally?

In Short: We may transfer, store, and process your Information in countries other than your own but will take all reasonable steps to ensure it is protected.

We store your data on third party servers which are based both in the UK and outside of the UK.

When working with third parties we may need to transfer your personal data outside of the UK and / or EU.

Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at [email protected] for more detail on this.

California Residents 

Residents of the State of California may ask us to provide them with (i) a list of certain categories of personal data that we have disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. California residents may make such one request per calendar year.

To make this request, you may contact us at [email protected]. Please use the subject line “CA Shine the Light Request” and in your communication, please confirm that you are a California resident and provide a current California mailing address for our response.

Third-party websites

In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the Platform.

The Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Platform. You should review the policies of such third parties and contact them directly to respond to your questions.

How long do we keep your information?

In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.

You may at any time review or change the information in your account. You may change your account name or email address on your account tab in the Howbout App. 

If you wish to terminate your account you must click on the “Delete account” button within the settings menu  in the Howbout App.  Some information may be retained in our files to prevent fraud, assist with any investigations, enforce our terms of use and/or comply with legal requirements. Any account information that is not required will be permanently deleted. 

When we have no ongoing business purpose to process your Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Do we collect information from minors?

In Short: We take steps to ensure that the Platform are only used by those over 13 years of age and we do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly solicit data from or market to children under 13 years of age. By using the Platform, you represent that you are at least 13 years of age. If we learn that personal information from users less than 13 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us at [email protected].

What are your privacy rights?

You may have certain rights under applicable data protection laws. including the right to: 

• access your personal data (also known as a “subject access request”);
• correct incomplete or inaccurate data we hold about you;
• ask us to erase the personal data we hold about you;
• ask us to restrict our handling of your personal data;
• ask us to transfer your personal data to a third party; 
• object to how we are using your personal data; and
• withdraw your consent to us handling your personal data.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you are based in the EU you can find your relevant supervisory authority here.

Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.

Accessibility

This Policy aims to provide you with all relevant details about how we process your Information in a concise, transparent, intelligible and easily accessible form, using clear and plain language. If you have any difficulty in reading or understanding this Policy, or if you would like this Policy in another format (for example audio, large print or braille), please get in touch with us.

Contact us

We welcome your feedback and questions on this Policy. If you wish to contact us please email us at [email protected]