Privacy Policy

1. Introduction

This Privacy Policy explains how Moseyaround Limited ("Mosey", "we", "our", or "us") collects, uses, stores, shares and protects personal information when you use the Mosey mobile application, website or related services.

It should be read alongside our:

• Terms & Conditions
• Cookie Policy
• Fair Play & Anti-Cheat Policy
• Rewards Terms
• Community Guidelines
• Security Statement

Together these documents form the Mosey Legal Centre.

2. Data Controller

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Moseyaround Limited is the Data Controller responsible for your personal information.

Being the Data Controller means we decide:

• what personal information is collected
• why it is collected
• how it is used
• how long it is retained
• with whom it is shared where necessary

Company Information

Moseyaround Limited

Company Number:

17337132

Registered Office:

66 Paul Street

London

EC2A 4NA

United Kingdom

Privacy Contact

Privacy enquiries should be sent to:

[email protected]

Legal Contact

Legal enquiries:

[email protected]

General Support

Customer support:

[email protected]

3. ICO Registration

Moseyaround Limited is committed to complying with the requirements of:

• the UK GDPR
• the Data Protection Act 2018
• the Privacy and Electronic Communications Regulations (PECR), where applicable

Our Information Commissioner's Office (ICO) registration number is:

000000

This placeholder will be updated once our ICO registration has been completed.

4. Our Privacy Principles

We believe privacy should be simple, transparent and respectful.

Whenever we process personal information we aim to ensure it is:

• processed lawfully
• processed fairly
• processed transparently
• collected only where necessary
• accurate and kept up to date
• retained only for as long as necessary
• protected using appropriate technical and organisational measures

These principles guide every feature developed for Mosey.

5. How UK GDPR Protects You

UK GDPR provides a number of rights regarding your personal information.

These include:

• the right to be informed
• the right of access
• the right to rectification
• the right to erasure
• the right to restrict processing
• the right to data portability
• the right to object
• rights relating to automated decision-making where applicable

Further details about exercising these rights are provided later in this Privacy Policy.

6. Our Lawful Basis for Processing

Whenever we process personal information, we ensure there is a lawful basis under UK GDPR.

Depending on the circumstances, this may include:

Contract

Where processing is necessary to provide the Mosey service.

For example:

• creating your account
• awarding Mosey Points
• processing reward redemptions
• operating community features

Legal Obligation

Where processing is required to comply with applicable laws.

For example:

• responding to lawful requests from public authorities
• maintaining financial records where required

Legitimate Interests

Where processing is reasonably necessary for the operation and improvement of Mosey and does not override your rights.

Examples include:

• fraud prevention
• platform security
• improving app performance
• analysing service reliability
• preventing abuse
• protecting other members

Consent

Where required by law, we will ask for your consent before processing personal information.

Examples may include:

• marketing emails
• optional notifications
• certain analytics or advertising technologies if introduced in future

You may withdraw consent at any time where consent is the lawful basis.

7. Data Processors

To provide the Mosey service, we use carefully selected third-party organisations that process information on our behalf.

These organisations act as Data Processors under contracts requiring them to process information only in accordance with our instructions and applicable data protection laws.

Examples include providers of:

• cloud infrastructure
• authentication
• analytics
• crash reporting
• communications
• customer support tools
• reward fulfilment
• survey services
• fraud prevention

Where personal information is processed by a third party on our behalf, we take reasonable steps to ensure appropriate contractual and security safeguards are in place.

8. Data Protection Officer

At the time of publication, Moseyaround Limited has not appointed a formal Data Protection Officer (DPO) because we are not legally required to do so.

Privacy responsibilities are managed internally.

If this changes, this Privacy Policy will be updated accordingly.

9. Contacting the ICO

If you believe we have not handled your personal information appropriately, we encourage you to contact us first so we can investigate and attempt to resolve your concerns.

You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK's independent authority for data protection.

Making a complaint to the ICO does not affect any other legal rights or remedies available to you.

10. Future Changes

As Mosey evolves, we may update this Privacy Policy to reflect:

• new features
• new technologies
• changes in legislation
• guidance issued by regulators
• operational improvements

Where significant changes are made, we will take reasonable steps to notify members before the updated Privacy Policy takes effect.

11. Categories of Personal Information

Depending on how you use Mosey, we may collect the following categories of information.

Not every member will provide every type of information.

12. Identity Information

When you create an account we may collect:

• Full name
• Display name
• Username
• Date of birth (to verify you are at least 18 years old)
• Profile photograph (if uploaded)

Purpose

To identify your account and provide the Mosey service.

Lawful Basis

Performance of a Contract.

13. Contact Information

We may collect:

• Email address
• Communication preferences

Your email address is used for:

• Account verification
• Password recovery
• Reward notifications
• Security alerts
• Legal notices
• Inactivity reminders
• Customer support
• Marketing communications (only where you have consented)

We will never sell your email address.

14. Address Information

At launch, Mosey only requires your postcode.

Your postcode is used to:

• Identify your general local area
• Show relevant local businesses
• Personalise offers and promotions
• Improve future community features
• Help prevent fraud

We do not use your postcode to determine your exact location.

We do not sell postcode information.

15. Authentication Information

Depending on how you register, we may receive information from authentication providers such as:

• Google
• Apple
• Email authentication

This may include:

• Name
• Email address
• Profile image
• Authentication identifier

Passwords supplied to third-party authentication providers are not visible to Moseyaround Limited.

16. Walking and Activity Information

Mosey has been designed to reward genuine physical activity.

Subject to your permissions, we may collect information such as:

• Daily step counts
• Walking activity
• Dates and times of activity
• Reward eligibility information

Where supported by your device, this information may be provided through:

• Apple Health
• Android Health Connect
• Other supported health platforms introduced in future

We do not collect unnecessary health information.

We only process the information required to calculate Mosey Points and operate the relevant features you choose to use.

17. Reward Information

To administer rewards we maintain records including:

• Points earned
• Points spent
• Reward redemptions
• Reward processing status
• Transaction references
• Redemption dates
• Reward history

These records help us:

• Process rewards
• Investigate issues
• Prevent fraud
• Maintain accurate account balances
• Meet legal and accounting obligations

18. Charity Donation Information

Where you choose to donate Mosey Points to a charity through the platform, we may record:

• Charity selected
• Donation amount
• Date of donation
• Transaction reference
• Completion status

We do not publish your individual donations unless you have expressly chosen to make them public through a feature we provide.

19. Survey and Offer Information

Where you participate in surveys or promotional offers we may receive information including:

• Offer participation
• Completion status
• Eligibility status
• Reward confirmation
• Technical identifiers required to prevent duplicate participation

Some survey information may be processed directly by third-party providers under their own privacy policies.

20. Community Information

Where community features are available we may process:

• Username
• Public profile image
• Achievement badges
• Leaderboard position
• Community participation
• Challenge history

Only information intended for community features will be visible to other users.

21. Customer Support Information

When you contact us we may keep records of:

• Emails
• Support requests
• Attachments you provide
• Investigation notes
• Complaint history
• Resolution history

This helps us improve support and maintain an accurate record of previous enquiries.

22. Technical Information

To help operate and improve Mosey we may automatically collect technical information such as:

• Device model
• Operating system version
• Application version
• Language settings
• Time zone
• IP address
• Device identifiers
• Crash reports
• Performance information
• Security logs

This information helps us:

• Improve stability
• Resolve bugs
• Detect fraud
• Protect accounts
• Improve compatibility

23. Usage Information

We may collect information about how members use Mosey.

Examples include:

• Features used
• Screens viewed
• Games played
• Challenges joined
• Reward interactions
• Time spent using the application

We use this information to improve the user experience and understand which features are most useful.

Where analytics require consent, we will obtain that consent before collecting the information.

24. Fraud Prevention Information

To protect members and the platform we may process information relating to:

• Suspicious login attempts
• Multiple account detection
• Device consistency
• Reward abuse
• Referral abuse
• Technical anomalies
• Security investigations

This processing is carried out only where reasonably necessary to protect Mosey and its members.

25. Information We Do Not Collect

At launch, Mosey does not intentionally collect:

• Bank account details
• Debit card information
• Credit card information
• Passport information
• Driving licence details
• Biometric information
• Medical records
• Precise GPS location (unless introduced as part of a future feature with appropriate notice and, where required, consent)

Should this change, we will update this Privacy Policy before the new processing begins.

26. Children's Information

Mosey is intended only for individuals aged 18 years or over.

We do not knowingly collect personal information from anyone under the age of 18.

If we become aware that personal information belonging to someone under 18 has been collected, we will take reasonable steps to investigate and, where appropriate, delete the account and associated information unless we are legally required to retain it.

27. Data Accuracy

We encourage members to keep their information accurate and up to date.

If any information held by Mosey becomes inaccurate, you should update your account or contact us as soon as reasonably practicable.

Accurate information helps us:

• Process rewards correctly
• Maintain account security
• Prevent fraud
• Provide effective customer support

28. How We Use Your Personal Information

We use personal information only where it is necessary to operate, improve and protect the Mosey platform.

The purposes described below are not intended to be exhaustive, but represent the principal ways in which your information may be used.

29. Providing the Mosey Service

We use your information to:

• create and manage your account
• authenticate your identity
• calculate and award Mosey Points
• process reward redemptions
• record charity donations
• display community features
• provide customer support
• maintain account security

Lawful Basis

Performance of a Contract.

30. Protecting the Platform

We process information to:

• detect fraud
• investigate suspicious activity
• prevent multiple accounts
• identify reward abuse
• investigate technical anomalies
• protect members from unauthorised access
• secure our systems

Lawful Basis

Legitimate Interests.

Protecting members and maintaining a fair rewards platform is an essential part of operating Mosey.

31. Improving Mosey

We continually analyse how the platform performs in order to:

• improve reliability
• resolve software bugs
• understand which features are most useful
• improve accessibility
• improve performance
• develop new features

Where required by law, we will request your consent before collecting optional analytics.

32. Reward Fulfilment

When you redeem a reward we process relevant information to:

• verify eligibility
• prevent fraud
• fulfil the reward
• maintain transaction records
• investigate failed redemptions
• comply with accounting obligations

Reward fulfilment may require information to be shared with trusted fulfilment partners acting on our behalf.

33. Charity Donations

Where you choose to donate Mosey Points, we process information necessary to:

• record your donation
• complete the donation
• maintain audit records
• report total donations where appropriate

Individual donations will not be publicly displayed unless you have specifically chosen to participate in a feature allowing this.

34. Customer Communications

We may use your contact information to send:

Essential Communications

• account verification
• password resets
• security alerts
• reward updates
• inactivity reminders
• changes to legal documents
• important operational announcements

These communications form part of the Mosey service and cannot generally be opted out of while you maintain an active account.

Optional Communications

Where you have provided consent, we may send:

• product news
• feature announcements
• promotions
• newsletters
• surveys

You may withdraw your consent at any time.

35. Compliance with Legal Obligations

We may process personal information where necessary to:

• comply with applicable laws
• respond to lawful requests from regulators
• comply with court orders
• prevent crime
• establish, exercise or defend legal claims

Lawful Basis

Legal Obligation.

36. Legitimate Interests

Some processing is necessary to operate Mosey effectively.

Examples include:

• fraud prevention
• cyber security
• service monitoring
• system testing
• customer support
• business continuity
• quality assurance

Whenever we rely on Legitimate Interests we consider the impact on members' privacy and seek to ensure that our interests do not override your rights.

37. Consent

Some activities require your consent.

Examples may include:

• optional marketing
• certain analytics technologies
• future location-based features
• optional health integrations beyond those required for the core service

Where consent is relied upon:

• it will be requested clearly
• it may be withdrawn at any time
• withdrawing consent will not affect processing already carried out lawfully

38. We Do Not Sell Personal Information

Moseyaround Limited does not sell your personal information.

We do not exchange your personal information for payment or other commercial benefit.

Where we use trusted service providers to operate Mosey, they process information on our behalf under contractual obligations and are not permitted to use your information for their own independent purposes unless you separately choose to engage with them.

39. Sharing Information

We may share limited personal information where necessary with:

• cloud hosting providers
• authentication providers
• reward fulfilment partners
• customer support systems
• fraud prevention services
• analytics providers (where appropriate)
• professional advisers
• regulatory authorities where legally required

We do not share more information than is reasonably necessary for the purpose concerned.

40. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes and protect the legitimate interests of Moseyaround Limited.

Retention periods may vary depending on the type of information.

Typical Retention Periods

Account Information

Retained while your account remains active.

If your account is deleted under our inactivity policy or at your request, we will normally delete or anonymise your personal information unless we are required or permitted by law to retain it.

Reward Records

Retained for as long as reasonably necessary to:

• investigate disputes
• comply with accounting obligations
• prevent fraud

Charity Records

Retained to maintain an accurate audit trail and comply with applicable legal obligations.

Customer Support Records

Retained for a reasonable period to assist with future enquiries, complaint handling and service improvement.

Security Logs

Retained only for as long as reasonably necessary to:

• investigate incidents
• maintain platform security
• prevent abuse

Legal Records

Certain information may be retained where necessary to:

• comply with legal obligations
• defend legal claims
• establish legal rights
• resolve disputes

41. Account Deletion

You may request deletion of your account at any time.

Following deletion:

• your profile will normally be removed
• unused Mosey Points will be forfeited in accordance with our Terms & Conditions
• completed reward records may be retained where legally required
• certain information may be retained for fraud prevention or legal compliance

We will not retain personal information indefinitely without lawful justification.

42. Future Processing

As Mosey develops, we may introduce additional features requiring new categories of processing.

Where this occurs we will:

• review our lawful basis
• update this Privacy Policy
• request consent where required
• notify members where appropriate

43. Your Rights Under UK GDPR

Subject to applicable law, you have the following rights regarding your personal information.

These rights are not absolute and may be subject to legal exceptions, but we will always consider requests fairly and in accordance with UK GDPR.

44. Right to Be Informed

You have the right to understand:

• what information we collect
• why we collect it
• how we use it
• who we share it with
• how long we keep it

This Privacy Policy is intended to satisfy that obligation in a clear and transparent manner.

45. Right of Access

You have the right to request confirmation of whether we process your personal information.

Where we do, you may request a copy of that information together with details including:

• the categories of information held
• why it is processed
• recipients or categories of recipients
• expected retention periods
• your legal rights

This is commonly known as a Subject Access Request (SAR).

46. Right to Rectification

If information we hold about you is inaccurate or incomplete, you have the right to request that it is corrected.

Where appropriate, you may also be able to update certain information directly within your Mosey account.

47. Right to Erasure

In certain circumstances you may request deletion of your personal information.

This right is sometimes known as the Right to be Forgotten.

Deletion may not always be possible where we are legally required to retain information, including for:

• fraud prevention
• accounting records
• legal obligations
• defending legal claims

Where information cannot be deleted immediately, we will explain why.

48. Right to Restrict Processing

In certain circumstances you may request that we temporarily restrict how we use your personal information.

Examples include:

• where you dispute its accuracy
• where processing is contested
• while a legal claim is investigated

During restriction we will generally continue storing the information but will limit further processing where required by law.

49. Right to Data Portability

Where processing is based on consent or the performance of a contract and carried out by automated means, you may request a copy of certain personal information in a structured, commonly used and machine-readable format where required by UK GDPR.

Where technically feasible, you may also request that information be transmitted directly to another organisation.

50. Right to Object

You may object to certain processing carried out on the basis of legitimate interests.

If you object, we will consider your request carefully.

We may continue processing where we have compelling legitimate grounds or another lawful basis recognised by UK GDPR.

You also have the right to object to direct marketing at any time.

51. Automated Decision-Making

Mosey may use automated systems to assist with functions such as:

• fraud detection
• identifying suspicious account activity
• duplicate account detection
• reward validation
• platform security

Important decisions affecting your account will not be based solely on automated processing where UK GDPR provides you with additional protections, unless permitted by law.

Where appropriate, you may request that certain decisions be reviewed by a person.

52. Exercising Your Rights

If you wish to exercise any of your privacy rights, please contact:

[email protected]

To protect your privacy, we may request additional information to verify your identity before responding.

We will only request information reasonably necessary to confirm your identity.

53. Response Times

We aim to respond to valid privacy requests as quickly as reasonably practicable.

In most cases, we will respond within one calendar month, as required by UK GDPR.

Where a request is particularly complex or multiple requests are submitted, this period may be extended where permitted by law.

If an extension is necessary, we will inform you and explain the reason.

54. International Data Transfers

Some of our trusted service providers may process personal information outside the United Kingdom.

Where this occurs, we take reasonable steps to ensure that appropriate safeguards are in place.

These safeguards may include:

• UK International Data Transfer Agreements (IDTAs)
• recognised adequacy regulations
• approved contractual clauses
• other safeguards recognised by UK data protection law

We will not transfer personal information internationally without an appropriate legal basis.

55. Protecting Your Information

Protecting your personal information is a fundamental part of operating Mosey.

We use a combination of technical and organisational measures designed to protect information against:

• unauthorised access
• accidental loss
• destruction
• alteration
• misuse
• unlawful disclosure

These measures are reviewed and updated as the platform evolves.

56. Security Measures

Depending on the nature of the information processed, security measures may include:

• encryption in transit
• encryption at rest where appropriate
• authenticated access controls
• role-based permissions
• secure cloud infrastructure
• monitoring for suspicious activity
• software updates
• audit logging
• secure backups
• vulnerability management

No internet-based service can guarantee absolute security, but we are committed to maintaining appropriate safeguards.

57. Personal Data Breaches

If we become aware of a personal data breach, we will investigate promptly.

Where required by UK GDPR, we will:

• notify the Information Commissioner's Office (ICO)
• notify affected individuals where legally required
• take appropriate steps to minimise any potential impact
• review our procedures to reduce the likelihood of recurrence

58. Making a Complaint

If you have concerns about how we handle your personal information, we encourage you to contact us first using:

[email protected]

We will investigate your concerns fairly and respond as soon as reasonably practicable.

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner's Office (ICO).

Contact details for the ICO are available on its official website.

59. Updates to This Privacy Policy

As Mosey develops, this Privacy Policy may be updated to reflect:

• new services
• changes in technology
• legal developments
• guidance issued by regulators
• improvements to our privacy practices

Where significant changes are made, we will notify members through appropriate channels before the updated policy takes effect where required by law.

60. Trusted Third-Party Providers

To operate Mosey safely and efficiently, we use carefully selected third-party providers.

These providers help us deliver services including:

• secure cloud hosting
• user authentication
• application performance
• crash reporting
• reward fulfilment
• customer support
• email communications
• fraud prevention
• analytics
• surveys
• charitable donation processing (where applicable)

Every provider is assessed before being used.

Where they process personal information on our behalf, they are required to comply with contractual data protection obligations.

61. Current Service Providers

At the Effective Date of this Privacy Policy, Mosey may use providers such as:

• Firebase (authentication, cloud database, cloud messaging and application services)
• Google Cloud (where applicable through Firebase)
• Cloudflare (website security, CDN and infrastructure protection)

Additional providers may be introduced as the platform develops.

An up-to-date list of significant service providers will be maintained within the Mosey Legal Centre or made available on request where appropriate.

62. Cookies and Similar Technologies

Our website and certain parts of the Mosey platform may use cookies or similar technologies.

These technologies help us:

• remember preferences
• maintain secure sessions
• improve performance
• understand website usage
• protect against fraudulent activity

Detailed information is available within our separate Cookie Policy.

Where required by law, we will request your consent before placing non-essential cookies or similar technologies on your device.

63. Analytics

Understanding how members use Mosey helps us improve the platform.

Where appropriate we may analyse information such as:

• application performance
• feature popularity
• crash statistics
• navigation patterns
• service reliability

Where analytics require consent under applicable law, consent will be requested before those analytics are enabled.

64. Marketing

Moseyaround Limited does not sell personal information for marketing purposes.

Where marketing communications are provided, they will normally be based upon:

• your consent
• existing customer relationships where permitted by law
• applicable marketing regulations

You may withdraw your marketing consent at any time.

65. Privacy by Design

Privacy is considered throughout the design and development of Mosey.

When developing new features, we aim to consider:

• data minimisation
• security
• transparency
• lawful processing
• user control
• proportionality

Where appropriate, privacy considerations are incorporated from the earliest stages of development rather than added afterwards.

66. Data Protection Impact Assessments (DPIAs)

Where a proposed feature is likely to result in a high risk to the rights and freedoms of individuals, Moseyaround Limited will consider whether a Data Protection Impact Assessment (DPIA) is required before the feature is introduced.

A DPIA helps us identify, assess and reduce privacy risks before new processing begins.

Not every new feature requires a DPIA, but we are committed to assessing privacy risks as part of our development process.

67. Staff and Confidentiality

Access to personal information is limited to individuals who require it to perform their duties.

Where appropriate, access is controlled through:

• role-based permissions
• authentication controls
• security monitoring
• confidentiality obligations
• least-privilege access principles

We regularly review access permissions to ensure they remain appropriate.

68. Data Accuracy and Quality

We take reasonable steps to ensure that personal information is:

• accurate
• complete where necessary
• relevant
• kept up to date

Members also play an important role by ensuring their account information remains current.

69. Version Control

This Privacy Policy forms part of the Mosey Legal Suite.

Whenever significant changes are made:

• a new version number will be issued
• the Effective Date will be updated
• a summary of material changes may be published where appropriate

Historic versions may be retained for audit and legal purposes.

70. Related Documents

This Privacy Policy should be read together with:

• Terms & Conditions
• Cookie Policy
• Rewards Terms
• Fair Play & Anti-Cheat Policy
• Community Guidelines
• Security Statement
• Third-Party Services Register
• Accessibility Statement

Together these documents form the Mosey Legal Centre.

71. Contact Us

For privacy enquiries:

[email protected]

For legal enquiries:

[email protected]

For customer support:

[email protected]

Registered Office:

Moseyaround Limited

66 Paul Street

London

EC2A 4NA

United Kingdom

Company Number:

17337132

ICO Registration Number:

000000 (to be updated once registration is complete).