Avis de Confidentialité - TiPJAR

Privacy Notice

This Privacy Notice ("Privacy Notice") sets out how Pocket Change Pioneers Ltd. (" TiPJAR") processes your personal data in connection with the operation of our business and your use of our websites at wearetipjar.com (" Site") and our mobile web or native applications ("Apps") (collectively, "Platforms") and the products and services we offer, including through our Platforms and at any physical locations ("Products and Services").

This version is effective from 1st March 2021.

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page.

  • Your access to and use of our Platforms, including your account page and any secure area, is subject at all times to our Terms of Use.

  • If you pay tips to our Clients, your use will be subject to our Customer Terms

  • If you collect tips through our Platform you use will be subject to our Client Terms.

  • If you provide permission to your employees to use our software in the course of their employment with your use will subject to our Operator Terms.

  1. Purpose of this privacy notice

    This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

    When we talk about "personal data", we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

    This Privacy Notice is intended to assist you in making informed decisions when using our Site and our Products and Services. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Use, our Client and Customer Terms and our Cookie Policy.

    This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

  2. About Us

    The Site and our Products and Services are made available by various companies in the TiPJAR group of companies (each a " Group Company").

    Where this Privacy Notice refers to " TiPJAR", " we", " us , " our", this means one or more of the particular Group Companies that provide the particular Platform or Products and Services to you.

    Except as stated otherwise, each Group Company is an independent controller of your personal data.

    Company Responsible for
    Pocket Change Pioneers Ltd. (company no: 11588402) is a company established under the laws of England and Wales with its registered office at215 Temple Chambers, 3-7 Temple Avenue, London, England, EC4Y 0HP. Development of our software including websites and Apps, providing support to other group companies and to clients, customers and operators in the UK and EU.
    TiPJAR Inc. (company no: 3081639) is a company established under the laws of Delaware, USA with its registered office at 1209 Orange St, Wilmington, New Castle County, Delaware 19801. Providing support to clients, customers and operators in the USA.
    TIPJAR Nordic A/S is a company established under the laws of Denmark. Providing support to clients, customers and operators in the EU and in Norway.
    TiPJAR Eire is company established under the laws of Ireland. Providing support to clients, customers and operators in the EU.
  3. How to contact us

    If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:

    On Site Contact us using our enquiry form
    Email Send us an email at support@wearetipjar.com
    Post Write to us at 215 Temple Chambers, Temple Avenue, London, EC4Y 0HP.
  4. What personal data we collect

    In providing our Site and our Products and Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Site and our Products and Services and includes the following:

    Identity Data First name; last name.
    Contact Data Delivery addresses; billing addresses; email address; telephone number; social media handles.
    Registration Data First name; last name; date of birth; gender; country; nationality; username; any KYC (Know Your Customer) information that we may collect confirming your identity and that you are engaging in an eligible activity to use our software; any other personal data that you may provide when you register an account with us.
    Employment Data If you receive tips with TiPJAR in the course of an employment, we may collect and process data about when and where you have worked to support tip sharing functionality.
    Financial Data Bank account details; and tokenized payment card details. We don't store your credit card details directly.
    Transaction Data Details about payments made between you and us; details of products purchased from us.
    Profile Data Account username; password; profile picture or avatar; purchase/order details; interests and preferences; contact preferences; whether you have participated in any promotions or competitions; feedback and survey responses; the content of any messaging you send using any Enquiry Form or Chat function on the Site.
    Behavioural Data Data relating to your browsing activity or interaction with our emails, obtained through the use of cookies, pixel tags and other similar technologies; information about when your current or previous sessions started; details about any products you viewed or purchased through the Site.
    Technical Data IP address; browser type and operating system; geolocation, to ensure we're showing you the correct notices and information; any other unique numbers assigned to a device.
    Marketing and Communications Data Marketing preferences; service communication preferences.
  5. How we collect and receive personal data

    We collect and receive personal data using different methods:

    Personal data you provide to us You may give us your personal data directly, for example, when you purchase products on our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.
    Personal data we collect using cookies and other similar technologies When you access and use our Site, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the "Insight, analysis and retargeting through Cookies" section below).
    Personal data received from third parties We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide our Site and our Services.
    Publicly available personal data From time to time, we may collect personal data about you (Identity Data, Contact Data or Profile Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).
  6. Who we collect personal data about

    We collect and process personal data from the following people:

    Site visitors If you browse our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
    Clients If you register with us to collect tips, we may collect and process your personal data to fulfil our obligations to you under our Client Terms.
    Customers If you tip using TiPJAR, we collect and process your personal data in order to collect your tip and pass it to the individual or team that you tipped, and inform them about your tip, including when and where you tipped and your name unless you choose to tip anonymously.
    Operators If you buy our Products and Services, we may collect and process your personal data in connection with the supply of goods or services to you.
    People who contact us with enquiries If you contact us with an enquiry through our Site, submit a complaint through our Site or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Site.
    People who work for our customers and suppliers If you work for one of our customers or suppliers and have responsibility for placing orders with us, administering your organisation's account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation's relationship with us.
    Visitors to our physical locations If you attend one of our physical stores, offices or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
    Event attendees If you attend an event hosted by us, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.
    Job applicants If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.
  7. How we use your personal data

    We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

    Use of our Site

    If you register and access an account on our Site You may be required to register an account with us in order to gain access to certain features and functionality of our Site and/or to receive certain offers and benefits. Account applicants will need to complete the registration form, providing all required Identity Data, Contact Data, Registration Data; Financial Data and Profile Data. We will use this data in order to process your registration. Once the account is registered, we will process your Identity Data, Contact Data, Registration Data and Profile Data to identify you when you log in to your account and access secure areas of our Site. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your account and contact you about your account. If you set a profile using our site, we may share your profile with other users of the site.We will also collect and process Behavioural Data and Technical Data when you use certain features and functionality on our Site. This data helps us understand how you use our Site so that we can improve it.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Site and our Products and Services in a secure and effective way and so that we can make improvements to our Site.
    If you purchase Products and Services on our Site We collect and maintain personal data that you submit to us for the purpose of supplying our Products and Services that you have requested from us via our Site. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent.The personal data we process may include your Identity Data, Contact Data, Registration Data, Profile Data, Financial Data and Transaction Data (where applicable). We process this information so that we can fulfil the supply of Products and Services, process any returns, maintain our user databases and to keep a record of how our Products and Services are being used.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products and Services, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that we provide our Products and Services in an effective, safe and efficient way.
    If you browse our Site When you browse our Site, we collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products and Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.
    If you use the interactive features on our Site We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data, Employment Data and Technical Data when you use the Enquiry Form or Chat function to get in touch with us or other account holders, or so that you can be searched for by other account holders.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.
    If you contribute to our Site or post content on our Site. If you create or contribute content to our websites, for example posting in a forum, writing or commenting on articles or blogs we send to our account holders and/or publish on our Site or in print, we may use your personal data (such as your Identity Data and/or Contact Details) to credit you for your contribution. If you provide photographs or other images in support of your post, we may publish one or more of those images alongside your comment, article or blog.If you submit any other content to us, including via our Site, such as photographs, quotes or testimonials, we may process any personal data comprised within that content for the purposes of making available particular Products and Services via our Site and promoting our Site and our Products and Services. We may also allow third parties to use the articles or blogs that you contribute, or the content that you provide (please see the "Content requests" section below). If the use of such content would involve the use of your personal data, we may use your Contact Details to ask your permission to use the relevant content, unless we are satisfied that we have a lawful right to use the content without your permission.

    Our legal basis for processing
    Where we use your content in connection with Products and Services that we provide via our Site, it is in our legitimate interest to use any personal data that you provide to us to ensure that we provide the relevant Products and Services in an effective way.Where we permit a third party to use your personal data contained within content that you submit, we will do so without your permission if we are satisfied that it is within our or the third party's legitimate interest to use your personal data, including to promote our Products and Services or products and/or services offered by the third party. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.
    If you request content from our Site Our Site features a "Content Request" function, which allows account holders and third parties to request access to and/or use of content, including photographs, quotes, testimonials, that has been published on our Site and/or which we otherwise hold. If you request content from us, we will ask you to complete the request form, providing your Identity Data, Contact Data, and any other information relevant to your request. We will process this information in order to process and respond to your request.

    Our legal basis for processing
    If you have requested content from us, it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that we process your request in an effective way.
    If you link to social media sites and interact with our social media pages If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any 'like' or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the "Insight, analysis and retargeting through Cookies" section below.The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.

    Our legal basis for processing
    It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.

    Ensuring the proper functioning of our Apps and providing you with our in-App features and notifications.

    If you use our Apps and associated features and functionality To ensure that our Apps can operate properly and provide you with the features you want, the provider of your mobile device may collect certain Technical Data. The data is automatically collected and transmitted to us from your device during your use of the Apps, (" Usage Data") and includes: (i) device name (e.g. "Apple iPhone" or "Samsung Galaxy" or any other name that you have given your device); (ii) operating system and version; (iii) system language; (iv) general device data, such as voice and regional settings; (v) IP address of the device; (vi) date and time of use; and (vii) application ID to identify your installation of the App.

    Our Apps may send us (or our IT suppliers) an error message in the event of a crash or other error (e.g. after the App has unexpectedly quit because of a program error or has stopped responding to your input). The error message contains Technical Data and information about which part of the App's software code has caused the error. This information helps us understand the cause of the error so that we can develop a fix to prevent that error from reoccurring and therefore improve the App for all users.

    When you open the Apps for the first time, you may be asked for permission to send you push notifications. If you allow this feature, our Apps will send you push notifications, for example, reminders, alerts, updates and other information. You can configure and turn off push notifications via your device settings at any time. You can also select the exact notifications you would like to receive using the in-app settings or browser settings.If you permit location settings, you will be asked if the App is allowed to access your location. If you allow this feature, we will determine your location to provide you with site-specific functions, like showing you which of our locations are close to you. You can configure and turn location settings off via your device settings at any time.

    If certain features require access to your camera or microphone, or photo and videos, or your phone contacts, you will be asked if you want to use this function and provide such access before using it for the first time. You can enable or disable access to these functions at any time via your device settings.

    Our legal basis for processing
    It is in our legitimate interest to use the Usage Data and send error messages (if applicable) in such a way in order to secure our Apps and to detect and resolve errors and cyberattacks.We rely on consent where you have enabled features such as push notifications, location, camera, microphone, or photo and video upload functions, as it will be your choice to receive such notification or allow us access to this information.

    Fulfilment of our Services.

    Fulfilment of our Services We collect and maintain personal data that you submit to us for the purpose of customers providing tips and gratuities to our clients and to ensure that tips are treated in the way our clients decide, which can include sharing those tips with others. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent. The personal data we process may include your Contact Data, Registration Data, and Financial Data (where applicable). We process this information so that we can fulfil the supply of Services, maintain our user databases and to keep a record of how our Services are being used. If you attend one of our locations, we will process personal data about you which you volunteer in connection with your visit and any enquiries you may have. This will usually include your Contact Data, and any other personal data you volunteer. Some Services we offer are also subject to separate terms and conditions which will also apply.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that we provide the Services in an effective, safe and efficient way.

    Customer service, enquiries and product returns.

    If you have a general question or need help with any issue concerning our Site or our Products and Services There are various ways in which you are able to contact us (see the "How to contact us" section above). In particular, our Site features a "Contact Us" page, which invites you to submit general enquiries about our Site by email or via our Enquiry Form. From time to time, you may also be able to submit specific enquiries on other pages of our Site, including in secure account areas. When you make an enquiry, we will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data and Transaction Data, as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Site, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry. We also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries.

    Our legal basis for processing
    It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.
    If you wish to claim a refund, return any of our Products or complain If you wish to claim a refund, return a Product you have purchased from us or complain about a Product or Service we have supplied, we will collect and process your Identity Data, Contact Data and, if applicable, certain Registration Data, Profile Data, Financial Data and Transaction Data, as well as any other personal data you volunteer that is relevant to your return. We use this information to assist you with your return or cancellation.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Products and Services, or it is in our legitimate interest to use personal data in such a way to ensure that we are able to help you with your return or cancellation, provide a good standard of service and improve our customer services.

    Surveys and feedback.

    If you complete our surveys or provide feedback on your experience of our Site and/or our Products and Services From time to time, we will invite you to provide feedback about us, our Site and our Products and Services in the form of online surveys. We will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data and Transaction Data, as well as any other personal data you choose to volunteer in your survey response or other feedback. We use this information to help us to monitor and improve our Site and our Products and Services, to assist with the selection of future product and service lines and to train our personnel.You can also voluntarily provide feedback by email or via our Enquiry Form. Please see the "Customer service, enquiries and product returns" section above for more information.

    Our legal basis for processing
    It is in our legitimate interest to use the personal data provided by you so that we can improve our Site and our Products and Services and provide them in an effective way.

    Hosting and managing events.

    If you sign up for and/or attend one of our events From time to time, we may organise and host events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you. If you attend one of our events, we may use your Identity Data, Contact Data and certain Profile Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.

    Our legal basis for processing
    It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party's legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

    Prize draws, prize competitions and other promotions.

    If you participate in one of our promotions From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Registration Data, Transaction Data, Profile Data, Behavioural Data and/or Technical Data and any other personal data volunteered by you in relation to your promotion entry. Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.

    Insight, analysis and retargeting through Cookies.

    If we use cookies to help us understand more about you and your use of our Site and our Products and Services We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access our Site, our Products and Services and any emails that you receive from us. The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data. Please see our Cookie Policy for further information, including details of our third-party partners.
    We and our third-party partners use this data to analyse how you use our Site and our Products and Services and the effectiveness of our Site and our Products and Services, including:
    • for the purposes described in the “If we carry out any online personalised advertising”, “If we advertise to you on social media and other platforms”, and the “If we advertise to other people who share similar interests and characteristics to you” sections below;
    • to analyse how you use, and the effectiveness of, our Site and our Products and Services;
    • to count users who have visited our Site or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site, our Products and Services and the effectiveness of our emails;
    • to measure the effectiveness of our content;
    • to learn what parts of our Site are most attractive to our users, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see;
    • to help us understand the type of marketing content that is most likely to appeal to our visitors and customers; and
    • to help us with the selection of future product and service lines, website design and to remember your preferences.
    In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

    Our legal basis for processing
    Where your data is collected through the use of non-essential cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Policy for further details.
    In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies,. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and our Products and Services.

    Advertising and marketing activities.

    If we send you marketing communications by post and/or email/SMS We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, our Site, our Products and Services, any events we may hold and the offers and promotions we offer from time to time.Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you. Where we are sending you personalised marketing, we may also use Profile Data, Transaction Data and Behavioural Data to help us decide what sort of personalised marketing to send you (please see the "Insight, analysis and retargeting through Cookies" section above for more details).

    Our legal basis for processing
    It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you. It is in our legitimate interest to use your personal data to send our marketing to you by post.However, we will only send marketing communications to you by email and/or SMS where you have consented to receive such content by email and/or SMS, or where we have another lawful right to send marketing to you using email and/or SMS. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email and/or SMS to consumers who have purchased our Products and Services. We may also rely on our legitimate interest to send marketing by email and/or SMS to certain business users of our Site and our Products and Services.
    If we carry out any online personalised advertising We and our third party partners may use your Profile Data, Behavioural Data and Technical Data and other data that is collected through your interactions with third party websites and services to provide you with, and analyse the effectiveness of, personalised ads when you visit other websites and/or use other services (including the social media and other platforms described in the "If we advertise to you on social media and other platforms" section below).By "personalised ads", we mean advertisements for products and services that you have shown an interest in when you have used our Site or which you otherwise might be interested in based on your browsing habits, although our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties.

    Our legal basis for processing
    Please see the "Insight, analysis and retargeting through Cookies" section above to learn about the legal basis that we rely on to collect data via the use of Cookies.Where we use your personal data to display online personal advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interests to promote our Site and our Products and Services to you.Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. Please read the privacy notice of the relevant third-party provider, as set out in our Cookie Policy [and/or our Cookie preference centre].
    If we advertise to you on social media and other platforms We share your email address (usually in an encrypted or 'hashed' form) with third-party providers of social media platforms and other services, such as Facebook, Snapchat, Sky and other similar platforms (" Social** Platforms"), so that the third party providers can try to "match" your data with the data of their registered users of their Social Platforms. Where there is a successful match, we will display our advertising to you when you use the relevant Social Platform (e.g. on your Facebook newsfeed). This is known as "custom audience" advertising, because we "customise" the audience that we want to reach on the relevant service.Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Profile Data and Behavioural Data, will not be provided to the third-party providers of the Social Platforms. Please see the "Insight, analysis and retargeting through Cookies" section above to learn more about how we personalise advertising to you. This activity is also subject to the privacy choices you have elected to make on such Social Platforms.

    Our legal basis for processing**
    We will only share your personal data with the third-party providers of the Social Platforms, so that we can advertise our Products and Services to you when you use those Platforms, where you have provided your consent.
    If we advertise to other people who share similar interests and characteristics to you We will provide your personal data to third-party providers of other services as described in the "Advertising to you on social media and other platforms" and the "Insight, analysis and retargeting through the use of Cookies" sections. If you are a user of those third-party services, we may ask the third-party providers of those services to find other registered users of their services who share similar interests and characteristics to you, which will be based on information that the third party holds about you and its other registered users.This is known as "lookalike" audience advertising because we are trying to show our advertising to people who "look like" you. Please note that such activity is also subject to the privacy choices you have elected to make on such third-party services.

    Our legal basis for processing
    It is in our legitimate interests to share your personal data with the third-party providers of other services so that we can advertise our Products and Services to other individuals that use those services and share similar interests and characteristics with you, although where this activity is undertaken through the use of Cookies please see the "Insight, analysis and retargeting through Cookies" section above) to learn about the legal basis that we rely on. You can opt-out of our sharing of your personal information with the third-party providers by exercising your rights as a data subject as set out below.

    Recruitment.

    If we use your personal data in connection with our recruitment activities We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment. We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.The personal data we process may include your Identity Data, Contact Data, Registration Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

    Our legal basis for processing
    Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions. We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

    Receipt of products and services from our suppliers.

    If we have engaged you or the organisation you represent to provide us with products or services If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Products and Services to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

    Our legal basis for processing
    It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide our Products and Services to others, in an effective way.

    Security.

    If we need to use your personal data in connection with the administration of our security measures We have security measures in place at our premises, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

    Our legal basis for processing
    It is in our legitimate interests to process your personal data so that we can keep our premises secure and provide a safe environment for our personnel and visitors to our premises.

    Business administration and legal compliance.

    If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.

    Our legal basis for processing
    Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
  8. If you fail to provide your personal data

    Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Products and Services you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant Products and Services to you, in which case we will notify you.

  9. How we obtain your consent

    Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the "How to Contact Us" section above.

  10. Third-party links

    This Privacy Notice only applies to personal data processed by us through your use of our Site and/or in connection with our business operations.However, from time to time, our Site may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.

    When you use a link to go from our Site to another website (even if you don't leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website's or third-party service provider's own rules and policies. For example, our Site invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

    We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

  11. Third-party app stores

    If you wish to download and install our Apps from an app store (such as Google Play or the Apple AppStore), you must first register with the provider of the respective app store), for a user account and agree to that app store's user agreement. We have no influence on the terms of such user agreement and are not a party to such user agreement. When downloading and installing one of our Apps, certain information is transmitted to the respective provider of the app store (e.g. Google or Apple) including your username, your email address and the customer number of your account, the time of download and the individual device code and, in the case of in-app purchases, your payment information. We have no influence on this process and are not responsible for you downloading and installing our Apps on your mobile device.

  12. Sharing personal data

    We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

    When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

    Third-party suppliers who provide applications/ functionality, data processing or IT services We share personal data with third parties who support us in providing our Site and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.
    Payment providers and banks We share personal data with third parties who assist us with the processing of payments and refunds.
    Delivery and courier companies We share personal data with suppliers who assist us in the delivery of our Products and Services to our customers.
    Advertising partners We share personal data with third party advertising partners, including those set out in our Cookie Policy[and/or our Cookie preference centre] when you use our Site[s]. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities.
    Third-party post/email marketing and CRM specialists We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.
    Third-party suppliers who assist us in administering our promotions We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.
    Event partners and suppliers When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.
    Hotel and transport operators and other travel-related businesses When you submit an enquiry to us about a hotel or transport provider, we will share your enquiry (including any personal data you volunteer) with that third party so that they can provide the information and assistance that you have requested.
    Recruitment agencies and related organisations We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.
    Auditors, lawyers, accountants and other professional advisers We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.
    Law enforcement or other government and regulatory agencies and bodies We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
    Other third parties Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
  13. Transfers outside the UK and the European Economic Area ("EEA") We are located in the UK, EU and USA and maintain servers globally to ensure the resilience of our services. Therefore, when you submit personal data to us, whether through your interactions with our Site and branch offices or our headquarters in the UK, you acknowledge that your personal data will be transferred outside the UK and the EEA where it will be stored and processed by us and our suppliers for the purposes set out in this Privacy Notice.

    Where necessary in order to provide our Site and our Products and Services, we will transfer personal data to countries outside the UK and the EEA.

    Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

    When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

    Adequacy decisions We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries\en.
    Model clauses Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries\en.
  14. How long we keep your personal data

    In respect of personal data that we process in connection with the supply of our Products and Services, we may retain your personal data for up to six years from the date of supply of the relevant Products and Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

    Where we process personal data in connection with the registration and use of an account on our Site, we may retain your personal data for up to six years from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

    Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protect obligations). We may then destroy such files without further notice or liability.

    If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

    If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

  15. Confidentiality and security of your personal data

    We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Products and Services.

  16. Personal data of minors

    Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, due to the nature of our organisation and the Products and Services we provide, we may from time to time collect and process personal data relating to minors. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

    If you are under the age of 18, you must not use our Site or purchase Products and Services from us and you must not provide us with any personal information. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the "How to contact us" section above).

  17. Your rights as a data subject

    You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the "How to Contact Us" section above.

    Your right of access If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
    Your right to rectification If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we've shared your personal data with so that you can contact them.
    Your right to erasure You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
    Your right to restrict processing You can ask us to "block" or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.
    Your right to data portability You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
    Your right to object You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else's legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
    Your rights in relation to automated decision-making and profiling You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
    Your right to withdraw consent If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the "How to Contact Us" section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
    Your right to lodge a complaint with the supervisory authority If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the "How to Contact Us" section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at http://ec.europa.eu/justice/data-protection/bodies/authorities/index\en.htm. As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner's Office (" ICO"). Contact details for the ICO can be found on its website at https://ico.org.uk.

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