Bin-Ovation Privacy Policy 

We ask that you read this privacy notice carefully as it contains important information on who we
are, how and why we collect, store, use and share personal information, your rights in relation to
your personal information and on how to contact us and supervisory authorities in the event you
have a complaint.

About Us

The Bin-Ovation App is an educational awareness tool that enables residents to access information
in respect of and/or also make contact with their Council’s Waste Management Scheme.
Bin-ovation Limited is a data controller of the personal information which we collect from and about
users of the Bin-Ovation App and/or the Services which we provided via the functions in the BinOvation
App. The Councils who subscribe to the Bin-Ovation App are also data controllers in respect
of the personal information which we provide to them via the operation of certain of the BinOvation
App Functions.

How is your personal information collected?
We collect personal information:

(1) Ourselves – through the Bin-Ovation Services on the Bin-Ovation App
 We collect information from and about you whenever you interact with certain Bin-Ovation
Functions. For example, if you initiate the Contact Council, Contact Bin-Ovation or Report It
Function on the Bin-Ovation App we may collect information about you, such as your name,
email address , phone number as well as any other information you provide in respect of
your contact with the council e.g. reason/type of contact and details of your query, request
or comment and/or in the case of the Report It Function, an optional photographic image of
the issue that you are reporting to your Council. This information may be shared with third
parties, including in particular your local Council for the same purposes. We may also collect
other Personal Information at the request of your local Council.

(2) Through other sources
 We may also collect information from your local council. For example, if upon first using the
Bin-Ovation App you select Ards & North Down Borough Council as your local council the
Auto-Reminders Function will automatically initiate and you will be given the option of
providing your address details to enable reminders to be set for you for your weekly bin
collection. In order to support the functionality of the Auto-reminders Function, Ards
Borough Council provide us with information via a spread sheet of the dates on which bin
collections are made from addresses in the council area.
 We and/or our third party service providers may store information that your computer or
mobile device provides to us in connection with your use of the Bin-Ovation App, such as
type of computer or mobile device, unique device identifier, IP Address, MAC address,
device’s operating system and/or physical location. You may disable our use of certain
location data through your device settings.
 We and/or our third party service providers may also store usage data such as the date and
time the application on your device accesses our servers, and what information have been
downloaded to the application based on your device number.

Reasons why we collect and use your Personal Information
We need to collect and use your Personal Information in order to provide the requested Bin-Ovation
Services. If you do not provide the necessary information, the requested Bin-Ovation Function may
not function correctly and/or we may not be able to provide that particular Bin-Ovation Service to
you.

How may your Personal Information be used?
We may use your Personal Information for legitimate business purposes, including:
• To provide the functionality of the Bin-Ovation Services and related support;
• To fulfil and record transactions, and provide you with related assistance (e.g., technical
assistance, etc.);
• To send administrative information to you, e.g. changes to our terms, conditions, and
policies;

We will engage in these activities to manage our contractual relationship with you and with your
consent. For example, in relation to the contractual relationship, where you have selected the
Report It Function and entered contact details and other details thereon, we need to use those
details in order process your report and, where appropriate deliver it to the Council. In relation to
consent, upon first downloading the App you are asked to confirm whether or not you consent to
push notifications.

• For reporting;
• For trending and statistics.

We will engage in this activity because we have a legitimate interest, namely to monitor and operate
our app efficiently and to improve our product and services. For example, we will rely on our
legitimate interest when we analyse what content/function has been viewed/used on our apps, so
that we can understand how they are used

• To accomplish our business purposes.
• For audits, to verify that our internal processes function as intended and are compliant with
any legal, regulatory or contractual requirements.
• For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks
or identity theft.
• For responding to legal duties, such as requests from public and government authorities.

We will engage in these activities to comply with a legal obligation or because we have a legitimate
interest.With respect to the processing of your Personal Information based on consent, this is the basis upon which we process personal information for the purposes of Push Notifications only, you may withdraw your consent and stop these notifications by deactivating the push notification function in your device settings.

Who we share your Personal Information with
We may disclose your Personal Information:
 To our third-party service providers including, GCD Technologies Limited, Apple, Amazon
and Google and other similar third parties who provide services such as website hosting,
data analysis, information technology and related infrastructure provision and other similar
services;
 To your Council if you are an End User and are using our Bin-Ovation Functions to interact
with your Council. Please contact your local Council/the Council you use the Bin-Ovation App
to interact with for more information as to their privacy practices;
 With law enforcement or other authorities if required by applicable law;
 We will not share your personal information with any other third party.

How long your personal information will be kept
We are currently reviewing our retention periods in conjunction with the Councils who subscribe to
the Bin-Ovation App and once finalised, this Privacy Notice will be updated accordingly.

Keeping your personal information secure
The security of Personal Information is a high priority for Bin-Ovation Limited. We seek to use
reasonable technical, administrative and physical safeguards to prevent personal information from
being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal
information to those who have a genuine business need to know it. Those processing your
information will do so only in an authorised manner and are subject to a duty of confidentiality.
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.

Your rights
Under the General Data Protection Regulation you have a number of important rights free of charge.
In summary, those include rights to:
• fair processing of information and transparency over how we use your use personal
information
• access to your personal information and to certain other supplementary information that
this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a
structured, commonly used and machine-readable format and have the right to transmit
those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
(note we do not process your personal information for the direct marketing)
• object to decisions being taken by automated means which produce legal effects concerning
you or similarly significantly affect you (note we do not carry our any automated processing
or profiling)
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see
the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the
General Data Protection Regulation.

If you would like to exercise any of those rights, please: email, call or write to our Data Protection
Officer whose contact details are provided in the Contact Us section below.

For your protection, we may only implement requests with respect to the Personal Information
associated with the particular email address that you use to send us your request, and we may need
to verify your identity before implementing your request.

We will try to comply with your request as soon as reasonably practicable however there may be
residual information that will remain within our databases and other records, which will not be
removed.

Please note that Bin-Ovation may need to forward your request and/or refer you to your Council
who may be better placed to address your request.
If you are a resident of one of the Councils who subscribe to the Bin-ovation App and would like
request the exercise of a right as set out above in relation to Personal Information held by your
Council, please contact your Council directly.

Your choices regarding our use and disclosure of information
Our mobile applications may send push notifications to your mobile device. If you have previously
consented to receiving push notifications and no longer wish to receive them, you can also turn push
notifications off at the device level via your device settings. The applications may also request access
to your device’s applications such as your calendar, gallery and camera. If you have previously
allowed access to these device applications and no longer wish to allow access, you may edit the
application settings at the device level.

Transfer of Data outside the EEA
Data we collect may be transferred to, stored and processed in any country or territory where one
or more of our service providers are based or have facilities. While other countries or territories may
not have the same standards of data protection as those in your home country, we will continue to
protect personal data that we transfer in line with this privacy policy.

Whenever we transfer your personal data out of the European Economic Area (EEA), we will ensure
similar protection and put in place at least one of these safeguards:
 We will only transfer your personal data to countries that have been found to provide an
adequate level of protection for personal data.
 We may also use specific approved contracts with our service providers that are based in
countries outside the EEA. These contracts give your personal data the same protection it
has in the EEA.
 Where we use service providers in the United States, we may transfer personal data to them
if they are part of the Privacy Shield scheme, which requires them to provide a similar level
of protection of your personal data to what is required in the EEA.

Changes to this privacy notice
This privacy notice was published 12th June 2018 and last updated on that date also. This privacy
notice is not contractual and we may make changes to it from time to time. When we do we will
inform you via a notification on the Bin-Ovation App.

Contact Details
If you have any questions regarding this Privacy Notice or how we handle personal information
please contact our Data Protection Officer Michael Brady via email to michael@bin-ovation.com

How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory
authority, in particular in the European Union (or European Economic Area) state where you work,
normally live or where any alleged infringement of data protection laws occurred. The supervisory
authority in the UK is the Information Commissioner who may be contacted at
https://ico.org.uk/concerns/ or telephone: 0303 123 1113.