GDPR Direct Collection Notice


Your personal data is being collected and processed by The Darwin Challenge Ltd (ACN 616 421 955) (we, us or our). We can be contacted by post at Level 4, Deutsche Bank Place, 126 Phillip St, Sydney NSW 2000, Australia or by email at Our representative within the European Union is Cosmin Bălaj of 2 Emil Isac, Apartment 9A, Cluj-Napoca, 400023, Cluj, Romania.

Information that we collect about you

As part of providing our application and our website to you, we collect your name and email address. If you choose to provide it, we may also collect details of the country that you live in.

Processing activities and lawful basis

We process the personal data that we collect from you for the purposes and on the applicable lawful basis set out in the table below:

Purpose of processing Lawful basis
To provide our application to you Performance of our contract with you as formed by your acceptance of the terms of use for our application
To enable you to access and use our mobile application Performance of our contract with you as formed by your acceptance of the terms of use for our mobile application
To operate, protect, improve and optimise our mobile application and services business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing For our legitimate interests in operating our business efficiently and effectively
To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you Your consent (if given to us)

Performance of our contract with you as formed by your acceptance of the terms of use for our website and our mobile application
To send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our supporters that we think you may find interesting Your consent (if given to us)
To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties Compliance with our legal obligations

For our legitimate interests in enforcing our contractual and legal rights

We collect personal data about you in order to provide our website and our mobile application to you. If you do not provide this personal data to us, we may not be able to provide our website and our mobile application to you or your use of our website and our mobile application may not be as helpful or enjoyable.

Third party recipients

As part of processing your personal data, We may disclose personal information for the purposes described in this Privacy Policy to:

  • our employees and to our volunteers in Australia, Romania, the United Kingdom, Germany, Bulgaria, India, Finland, the United States of America and the Netherlands;

  • third party suppliers and service providers (including providers for the operation of our website and/or in connection with providing our mobile application and website to you);

  • our professional advisers, dealers, business partners and agents;

  • specific third parties authorised by you to receive information held by us; and/or

  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law

We may hold and disclose your personal data outside of the European Union. In particular, we may hold personal information collected about you in Australia, India and the United States of America.

Overseas recipients

In addition, we may disclose personal information to a range of service providers (including but not limited to: Apple, Amazon Web Services, MixPanel, Work in Progress and Priya) that are located outside of, or may store personal information outside of, the European Union, including but not limited to the USA, Australia and India. When we disclose personal information to these third parties, we do so on the basis of adequate safeguards being put in place to protect your personal data.

  • an adequacy decision under Article 45(9) of the GDPR in respect of the EU-US Privacy Shield Framework for any US-based third party who has self-certified its compliance with the EU-US Privacy Shield Framework to the US Department of Commerce (details of the relevant safeguard can be accessed via by searching for the name of the recipient as listed above); or

  • otherwise on the basis of a data transfer agreement with that third party that implements standard data protection clauses as permitted under Article 46.2 of the GDPR (details of the relevant safeguard can be obtained upon request by sending an email to

Storage of personal data

We will store your personal data for so long as we continue to provide our application and/or our website to you. After this time, we will continue to store your personal data to the extent required by any law applicable to our business or for compliance and risk management purposes. We will delete or de-identify your personal data when it is no longer necessary or required to be kept.

Your rights

Where we process any personal data about you on the basis of any consent given by you, you have the right to withdraw your consent at any time by giving notice to us (which you can do using our contact details set out above). We will give effect to your withdrawal of consent promptly and will cease any processing that you no longer consent to, unless we have another lawful basis for that processing. The withdrawal of your consent will not affect the lawfulness of any processing that occurred prior to the date that you notified us that you were withdrawing your consent.

You have the right to request access to a copy of the personal data that we hold about you and to request that we correct or rectify any inaccurate personal data that we hold about you. You also have a right to data portability, which is the right in certain circumstances to request a copy of your personal data in in a structured, commonly used and machine-readable format and to transmit this data to another data controller. You may also request that we erase any personal data that we hold about you which is no longer necessary for any of the purposes that we collected it for, which you have withdrawn your consent in respect of or processing which you are allowed under the GDPR to object to. We will comply with such requests unless we are permitted or required by law to retain that information. You also have the right to object to our processing of personal data in certain circumstances, including where we process personal data based on our legitimate interests. You can also request that we restrict our processing activities in some circumstances. If you make such a request in those circumstances, then we will continue to store your personal data but will not otherwise process your personal data without your consent or as otherwise permitted by law.

You have a right to lodge a complaint in respect of our processing of your personal data with the data protection supervisory authority in the member state of the European Union that you ordinarily reside or work in.

For more information on our processing of your personal data, please see our Privacy Policy, which is available at

Effective: 25 May 2018