Walsh London Ltd ("WLL", "we", "us", "our") is a company registered in England and Wales, company number 16949730. We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Data We Collect
1.1 Non-Personal Data
When you use our apps, we and our third-party analytics partners automatically collect non-personal data about your device and usage. This data is aggregated and de-identified and cannot be used to identify you individually. It may include:
- Device type, operating system, and firmware version
- App version and unique installation identifier
- Usage data (e.g. features accessed, in-app interactions)
- Country or region settings
- Crash and performance diagnostics
On iOS devices, we may access Apple's Advertising Identifier (IDFA) only where you have granted permission via Apple's App Tracking Transparency (ATT) prompt. If you decline ATT permission, no advertising identifier is collected. On Android, the Google Advertising ID may be collected subject to your device advertising preferences.
1.2 Personal Data
We collect personal data only in the following circumstances:
- When you contact us for technical support — name and email address
- When you register for in-app competitions or partner services — which may include name, email address, phone number, address, date of birth, and/or gender as required by the specific service
- When you request that WLL saves your app settings (Android) — account identifier and preferences
We will not require you to provide personal data beyond these situations. Where your personal data is linked to your advertising identifier, all data described in Section 1.1 also constitutes personal data and is handled accordingly.
2. Purpose and Legal Basis for Processing
2.1 Provision of Services
To provide the core app functionality, technical support, and app settings saving, WLL processes your personal data as necessary for the performance of a contract with you (Article 6(1)(b) UK GDPR). Where services are provided by our partners (e.g. in-app competitions), WLL processes your personal data as a processor on behalf of those partners.
2.2 Analytics
We use aggregated, non-personal analytics data to understand how users interact with our apps and to improve their performance. The legal basis for this processing is our legitimate interest in maintaining and improving our services (Article 6(1)(f) UK GDPR). This processing does not use identifiable personal data.
2.3 Marketing and Advertising
Where you have granted permission via the ATT prompt (iOS) or equivalent device-level consent (Android), we or our advertising partners may serve you relevant advertisements within the apps. The legal basis for personalised advertising using your advertising identifier is your consent (Article 6(1)(a) UK GDPR / UK PECR). You may withdraw consent at any time by adjusting the advertising settings on your device, or by resetting/limiting your advertising identifier in your device settings. Withdrawal will not affect the core functionality of the apps.
Where no consent has been given, only non-personalised, contextual advertising may be displayed.
3. Children's Data
Our apps are not directed at children under the age of 13, and we do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at privacy@walsh.london and we will promptly delete the data.
Users aged 13–17 may use the apps with parental or guardian consent. We apply additional care to data relating to users in this age range and do not use it for behavioural advertising purposes.
4. Third-Party Processors and Partners
Your data may be processed by the following categories of third parties acting on WLL's behalf or in connection with our services, under appropriate data processing agreements:
- Analytics providers (e.g. Firebase / Google Analytics for Firebase) — to collect aggregated usage and crash data
- Cloud infrastructure providers (e.g. Firebase, AWS) — to store app data and deliver services
- Competition and partner service providers — where you opt in to in-app partner services
- Advertising networks — solely where you have granted ATT / advertising consent
WLL may also disclose your personal data in connection with a merger, acquisition, or sale of assets, or to authorities where required by law.
5. International Data Transfers
WLL's services rely on cloud infrastructure and third-party processors that may transfer your data outside the UK, EU, and EEA — including to the United States. All such transfers are conducted under appropriate safeguards, including Standard Contractual Clauses as recognised under UK GDPR and the UK International Data Transfer Agreement (IDTA), or other lawful mechanisms approved by the ICO. By using our apps, you acknowledge that your data may be transferred internationally under these safeguards.
6. Data Retention
- Technical support data — retained for up to five years after your support request is resolved
- App settings data (Android) — retained for as long as you maintain the saved settings or request deletion
- Partner sign-up data — retained for no longer than one year after the service has been provided, or as directed by the partner
- Marketing / advertising data — retained for no longer than three years from your last active use of the services
- Analytics data — retained in aggregate form in accordance with our analytics providers' standard policies
Personal data may be retained longer where required by applicable law or regulatory obligation.
7. Your Rights
Under UK GDPR, you have the right to:
- Access — obtain a copy of the personal data we hold about you
- Rectification — have inaccurate data corrected
- Erasure — request deletion of your data in certain circumstances
- Restriction — ask us to limit processing in certain circumstances
- Portability — receive your data in a structured, machine-readable format where processing is based on consent or contract and carried out by automated means
- Objection — object to processing based on legitimate interests, including direct marketing
- Withdraw consent — where processing is based on consent (e.g. advertising identifier use), you may withdraw at any time via device settings, without affecting prior processing
To exercise any of these rights, or for any privacy-related queries, please submit a written request to: privacy@walsh.london. We will respond within one month. If your request is manifestly unfounded or excessive, WLL may charge a reasonable administrative fee or decline to act, with written reasons provided.
You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
8. Automated Decision-Making
We do not carry out any automated decision-making or profiling that produces legal or similarly significant effects on you.
9. Changes to This Policy
WLL may update this privacy policy from time to time. Material changes will take effect no earlier than 30 days after you have been informed via a notice within the app(s) or other reasonable notification method. Continued use of the apps after this period constitutes acceptance of the updated policy.
10. Contact
Walsh London Ltd · Company No. 16949730
Email: privacy@walsh.london
Last updated: March 2026 · Walsh London Ltd · No. 16949730