Privacy Notice

1. Important Information and Who We Are

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Digital Rewards Group Limited collects and processes your personal data through your use of this website and app, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended to be used by children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Digital Rewards Group Limited along with trading names of Digital Rewards Group is the controller and responsible for your personal data (collectively referred to as Digital Rewards Group, "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by using the details set out below.

Contact Details

Full name of legal entity: Digital Rewards Group Limited

Name or title of contact: Danielle Walker (Operations Director)

Email address: [email protected]

Postal address: Charter House, 2 Woodlands Road, Altrincham, WA14 1HF

Telephone number: 0161 244 8225

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and Your Duty to Inform Us of Changes

This version was last updated on 24th May 2018 and can be obtained by contacting us.

The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy notice of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes: first name, last name, username or similar identifier, number of children, child ages, title, and gender.
• Contact Data includes: billing address, delivery address, email address and telephone numbers.
• Financial Data includes: payment card details.
• Transaction Data includes: details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website or app.
• Profile Data includes: your username and password, purchases or orders made by you, your interests, preferences, feedback, and personal interactions with us including emails, telephone calls and recordings.
• Usage Data includes: information about how you use our website, products and services.
• Marketing and Communications Data includes: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website/app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website/app;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google (based outside the EU);
    • advertising networks such as Facebook, Twitter, Instagram (based outside the EU);
    • search information providers such as Google (based outside the EU).
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our payment providers or The Royal Mail (inside and outside the EU).

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party or direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on where more than one is listed.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your personal data use by following personal data control mechanisms:

Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services, or provided your details when entering a competition or registering for a promotion and, in each case, you have not opted out.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside of Digital Rewards Group for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by:

• Emailing [email protected]
• Checking or unchecking relevant boxes in your account preferences
• Following the opt-out links in any marketing message
• Contacting us directly

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table in paragraph 4 above OR such as SPECIFIC THIRD PARTIES.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions.

6. International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the data
• The potential risk of harm from unauthorised use or disclosure
• The purposes of processing and whether these can be achieved in other ways
• Applicable legal requirements

Retention periods for specific data types are outlined in our retention policy, available upon request. By law, we must keep basic information (including Contact, Identity, Financial and Transaction Data) for five years after a customer relationship ends for tax purposes.

In some circumstances you can ask us to delete your data — see Request erasure below. In others, we may anonymise your personal data for research or statistical purposes, in which case we may use it indefinitely without further notice.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing
• Request transfer of your personal data
• Right to withdraw consent

If you wish to exercise any of the rights above, please contact us.

No Fee Usually Required

You won't usually have to pay to access your data (or exercise other rights), but we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We may also refuse to comply in these cases.

What We May Need from You

We may request specific information to confirm your identity and right to access your data (or exercise any rights). This is a security measure to ensure personal data isn’t disclosed to anyone not entitled to it. We may also contact you for further information to speed up our response.

Time Limit to Respond

We aim to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is complex or if you've made multiple requests. We'll keep you informed.

10. Glossary – Lawful Basis

Legitimate Interest

This means our interest in conducting and managing our business to provide you the best service and secure experience. We make sure we balance your rights and any impact on you before relying on this basis. We don’t use your data where our interests are overridden by the impact on you (unless we have consent or are required by law).

Performance of Contract

Processing your data where necessary for a contract with you, or to take steps at your request before entering into one.

Comply with a Legal or Regulatory Obligation

Processing your personal data where required for compliance with a legal or regulatory obligation we’re subject to.

Third Parties

Internal Third Parties

Other companies or trading names of Digital Rewards Group Limited based in the UK who provide IT and system administration services and leadership reporting.

External Third Parties

• Service providers acting as processors based inside the EU who may provide IT and system admin services.
• Professional advisers (lawyers, bankers, auditors, insurers) who provide consultancy, legal, banking, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers in the UK who require reporting of processing activities.

Your Legal Rights (Expanded)

• Request access: Receive a copy of the personal data we hold and check we are lawfully processing it.
• Request correction: Request correction of inaccurate or incomplete data (we may need to verify new data).
• Request erasure: Ask us to delete personal data where there is no good reason for continued processing, or if unlawfully processed, or to comply with law. We may not always be able to comply for specific legal reasons.
• Object to processing: Where we rely on legitimate interest and you feel it impacts your rights/freedoms. Also applies to direct marketing. In some cases, we may demonstrate compelling legitimate grounds.
• Request restriction: Ask us to suspend processing if (a) you contest the accuracy, (b) use is unlawful but you don’t want erasure, (c) you need it held to establish, exercise or defend claims, or (d) you’ve objected and we're verifying legitimacy.
• Request transfer: Receive your data or ask us to transfer it to a third party. Applies only to automated data provided under consent or contract.
• Withdraw consent: Withdraw consent where we rely on it to process your data. This does not affect processing done before withdrawal. Some services may not be provided if consent is withdrawn.