1. Introduction

This Privacy Policy explains how SetSum Ltd (“we”, “our”, or “us”) collects, uses, and protects your personal information when you use our mobile application (“the App”) and our website at https://setsum.co.uk (“the Website”). We are committed to protecting your personal data and ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. By using our App or Website, you agree to this Privacy Policy.

2. Who We Are

SetSum Ltd is a private limited company registered in England and Wales. We operate the SetSum App and associated services designed to help supporting artistes calculate and track estimated earnings.
For any data protection queries, contact:
Email: support@setsum.co.uk
Website: www.setsum.co.uk
SetSum Ltd is registered with the Information Commissioner’s Office (ICO) under registration number ZC027555

3. Data We Collect

We collect only the data necessary to operate our services effectively and securely.
– Account Information: Name, email address, password, and date of birth (to verify that you are over 16).
– App Usage Data: Pay rate selections, shift logs, calculation inputs, preferences, and interaction data.
– Device and Technical Data: Device type, operating system, and performance information.
– Optional Data: Profile photo or personal notes you choose to add.
We do not collect or store any payment card, bank account, or sensitive personal data.

4. How We Use Your Data

We use your data to:
– Operate, maintain, and improve the App and Website.
– Display, calculate, and store user-entered shift and pay information.
– Verify age eligibility (16+ users only).
– Respond to enquiries, technical support, and feedback.
– Send essential service updates.
– Monitor anonymised analytics via app store platforms (Apple App Store, Google Play Console).
– Comply with legal and regulatory obligations.
We do not sell, rent, or trade personal data.

5. Legal Basis for Processing

We process your data under the following lawful bases:
– Contractual Necessity: To provide and operate your account and App functionality.
– Legitimate Interests: To maintain security, analyse performance, and enhance user experience.
– Legal Obligation: To comply with applicable laws, including age verification.
– Consent: For optional features such as uploading a profile picture or receiving communications.

6. Automated Decision-Making

SetSum uses automated processes to perform calculations based on user-provided inputs. These processes are for informational purposes only and do not constitute automated decision-making that produces legal or similarly significant effects.

7. Data Storage and Security

Your data is stored securely using encryption and restricted access measures. Hosting is provided through DigitalOcean (and may migrate to Amazon Web Services in future) under GDPR-compliant safeguards.
We take appropriate technical and organisational measures to protect data against unauthorised access, alteration, or disclosure. In the unlikely event of a personal data breach, we will notify affected users and relevant authorities as required by law.

8. Data Retention and Account Deletion

We retain personal data only for as long as necessary to fulfil the purposes described in this policy or as required by law. Inactive accounts may be removed after 24 months.
You can delete your account at any time through the App or by contacting support@setsum.co.uk. Once deleted, personal data is permanently removed unless retention is legally required (e.g., for fraud prevention or dispute resolution).

9. International Data Transfers

Some service providers may store or process data outside the UK or European Economic Area (EEA). In such cases, SetSum Ltd ensures appropriate safeguards are in place — including Standard Contractual Clauses (SCCs) approved by the ICO — to protect your rights and data integrity.

10. Sharing and Third Parties

We may share limited data with trusted third parties solely for operational purposes, including:
– Hosting and cloud infrastructure providers.
– Analytics and performance platforms.
– Legal or regulatory authorities when required by law.
All third parties are bound by strict confidentiality and data protection obligations under written agreements.

11. Cookies and Tracking

Our Website and App may use cookies or similar technologies to enhance functionality and collect anonymous analytics.
– Essential Cookies: Enable login sessions and secure operation.
– Analytics Cookies: Collect anonymised usage data to improve performance.
You can manage or disable cookies through your browser or device settings at any time.

12. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:
– Access to your information.
– Correction of inaccurate or incomplete data.
– Erasure of personal data (“right to be forgotten”).
– Portability of your data to another service provider.
– Objection to processing under certain lawful bases.
– Withdrawal of consent for optional processing (e.g., profile photo).
To exercise these rights, email support@setsum.co.uk. We respond within one month of receipt.

13. Children’s Privacy

SetSum is not intended for users under the age of 16. We verify user age during registration and delete any accounts found to belong to underage individuals.

14. Data Breach Response

If a data breach occurs, SetSum Ltd will:
– Investigate and contain the breach immediately.
– Notify affected users without undue delay.
– Report the incident to the ICO within 72 hours where legally required.

15. Complaints

If you believe your data has been handled improperly, please contact us at support@setsum.co.uk. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) via www.ico.org.uk.

16. Updates to This Policy

We may update this Privacy Policy periodically to reflect legal, technical, or operational changes. The latest version will always be available within the App and on our Website. Significant updates will be communicated directly to users.

17. Contact Information

SetSum Ltd
Email: support@setsum.co.uk
Website: www.setsum.co.uk
Registered in England and Wales.