BAGGED2U LTD

BAGGED 2U PRIVACY POLICY

 

Introduction

Welcome to Bagged2U Ltd’s privacy policy.

Bagged2U Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you register to use our app and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the [Glossary] to understand the meaning of some of the terms used in this privacy policy.

  1. ​IMPORTANT INFORMATION AND WHO WE ARE

  2. ​THE DATA WE COLLECT ABOUT YOU

  3. ​HOW IS YOUR PERSONAL DATA COLLECTED?

  4. ​HOW WE USE YOUR PERSONAL DATA

  5. ​DISCLOSURES OF YOUR PERSONAL DATA

  6. ​INTERNATIONAL TRANSFERS

  7. ​DATA SECURITY

  8. ​DATA RETENTION

  9. ​YOUR LEGAL RIGHTS

  10. ​GLOSSARY

1. Important information and who we are Purpose of this privacy policy

This privacy policy aims to give you information on how Bagged2U Ltd collects and processes your personal data through your use of this app, including any data you may provide through the app when you purchase a product.

The app is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller
Bagged2U Ltd (referred to as ​Bagged2U,​ ​we​, ​us or ​our in this privacy policy) is the controller and responsible for your personal data.

Whenyoupurchasegoodsfromretailersthroughourapp(​Retailers)​,wewill–asdiscussedfurtherbelow–sharesomeof your personal data with the Retailers in order for them to fulfil your purchase, handle returns etc. Each Retailer will provide you with their own privacy policy at check-out. In relation to the personal data which we share with them and they then hold about you (as well as any other data about you that they collect), they are a controller and are separately responsible for how they deal with that personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise ​[your legal rights], please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address: info@bagged2u.com
Postal address: 41 Corsham Street, Hoxton, London, N1 6DR

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ​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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 16th of July 2019.

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

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

1. 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:

  • Communications Data​ includes feedback, instant messaging communications and survey responses;

  • Contact Data​ includes billing address, delivery address, email address and telephone numbers;

  • Identity Data​ includes first name, last name, username (or similar identifier), title, date of birth and gender;

  • Marketing Data I​ncludes your preferences in receiving marketing from us;

  • Profile Data I​ncludes your username and password, your interests, preferences;

  • Technical Data includes internet protocol (IP) address, login data, time zone setting and location, operating system and platform and other technology on the devices you use to access our app;

  • Transaction Data includes details about payments to and from you and details of purchases or orders made by you (including details of the products you have purchased from Retailers, order numbers, confirmation of deliveries, returns and credit/debit card details) as well as any referrals to us by you and (where applicable) your referral to us by a third party;

  • Usage Data i​ncludes information about how you use our app.

    We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific 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 policy.

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 an order you have placed through 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, Profile, Marketing and Communications Data by filling in forms, selecting options within our app or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o create an account on our app;

o purchase goods from Retailers;

o request marketing to be sent to you (or opting out of receiving marketing);

o enter a competition, promotion or survey; or

o give us feedback or contact us.

We will also obtain certain Transaction Data when you make purchases from Retailers (for example, what goods you have purchased).

  • ●  Automated technologies or interactions. As you interact with our app, we will automatically collect Technical and Usage Data about your device, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our [​ cookie policy]​ below for further details.

  • ●  Third parties.​ We will receive personal data about you from various third parties as set out below:

4.

o o

certain Transaction Data from Retailers and our delivery drivers (for example, whether the goods have been delivered or returned); and

certain Transaction Data from ​[Bagged2u Stripe] (​Stripe)​ (for example, confirmation of payment). (Stripe will collect and process other personal data (for example, credit/debit card details) in relation to transactions but will not transfer this to us.)

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 obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although – where we do – you have the right to withdraw consent at any time.

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; and

    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 to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

(a) Identity (b) Contact

Performance of a contract with you

To process and deliver your order (as well as any returns), including:

(a) managing payments, fees and charges, including sharing your personal data with Stripe

(b) sharing your personal data with Retailers and our drivers

(b) collecting and recovering money owed to us and/or Retailers

(a) Identity
(b) Contact
(c) Transaction
(d) Communications

(a) Necessary for our legitimate interests (including obtaining payments from you due to us, recovering debts due to us)

(b) Necessary for Retailers’ legitimate interests (including obtaining payments from you due to Retailers, assisting Retailers in performing their contracts with you and recovering debts due to Retailers)

To manage our relationship with you which will include:

(a) notifying you about changes to our terms or privacy policy

(b) asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing
(e) Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our app/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing
(f) Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and to promote and develop our business)

To display ‘leader boards’ in our app for the highest:

(a) charitable donations made on purchases via our app;

(b) referrals made to us by our users.

(a) Profile
(b) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and to promote and develop our business)

To administer and protect our business and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity (b) Contact (c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing
(f) Communications (g) Technical

Necessary for our legitimate interests (to study how customers use our app/services, to develop them, to develop our business and to inform our marketing strategy)

To use data analytics to improve our app/services, marketing, customer relationships and experiences

(a) Technical (b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our app updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about products/services and offers that may be of interest to you

(a) Identity
(b) Contact
(c) Technical (d) Transaction (e) Usage

(f) Profile
(g) Marketing
(h) Communications

Necessary for our legitimate interests (to develop our products/services and develop our business)

To create aggregated/anonymised data

(a) Identity
(b) Contact
(c) Transaction
(d) Technical
(e) Profile
(f) Usage
(g) Marketing
(h) Communications

Necessary for our legitimate interests (to allow us to freely use the aggregated/anonymised data in the future to define types of customers for our products and services, to keep our app updated and relevant, to develop our business and to inform our marketing strategy)

Marketing from us

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

You will receive marketing communications from us if you have requested it from us and have not subsequently opted out of receiving that marketing.

Third-party marketing

We will not share your personal data with any third party for marketing purposes.

Opting out

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

  • ●  logging into our app and checking/unchecking the relevant boxes in the profile settings;

  • ●  by following the opt-out links on any marketing message sent to you; or

  • ●  by contacting us at any time.

    Where you opt out of receiving these marketing messages, this will only apply to marketing (and not to other uses/processing, although – as discussed below – you may also [​ object to our processing of your personal data]​ for other purposes).

    Cookie policy

    We use a single tracking technology. This technology enables us to:

  • ●  recognise the copy of our app installed on your device (i.e. to remember you) so that you don’t have to log in to our app every time you use it; and

  • ●  collect Technical Data which is essential for our app to function.

    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 we will 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 share your personal data with the parties set out below for the purposes set out in the table above.

  • ●  Internal Third Parties, as set out in the​ [Glossary].

  • ●  External Third Parties as set out in the [Glossary].

● 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, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 your personal data for specified purposes and in accordance with our instructions.

6. International transfers
We do not transfer your personal data outside the European Economic Area (the E​ EA)​ .

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

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

3. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means (as well as the applicable legal, regulatory, tax, accounting or other requirements).

Details of retention periods for different aspects of your personal data are set out below:

Type of Data Retention Period

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ity, Profile, Marketing, Transaction and Communications

The earlier of:

  1. (a)  when you request that we stop processing that data;

  2. (b)  four years after you last used our app and you have not responded to our request to confirm that you still wish to retain your account (in which case, we will close your account);

  3. (c)  when we or you close your account for any other reason,

assuming (in each case) we have no justification to keep processing the data.

Technical and Usage

The earlier of:

  1. (a)  when you request that we stop processing that data;

  2. (b)  one year after the relevant data was originally collected;

  3. (c)  when we or you close your account for any other reason,

assuming (in each case) we have no justification to keep processing the data.

Ident

In some circumstances you can ask us to delete your data: see [​ your legal rights] ​​be​ low for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or

statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact our data privacy manager using the details specified in

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES Internal Third Parties

● Delivery drivers, engaged by us to deliver your orders from Retailers to you.

External Third Parties

● Service providers (acting as processors) based in the EEA who provide IT and system administration services, namely:

o

o

o
● Retailers.

YOUR LEGAL RIGHTS

You have the right to:

Appwox Limited who provide website and app development, maintenance and support services; Stripe who provide our payment processing services.

​Amazon Web Services EMEA SARL ​who provide various IT services. For example: data hosting and remote server services; database services; application programming interface services; user sign-up and registration services; messaging services;

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● ●

request access ​to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

request correction ​of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

request erasure ​of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

object to processing ​of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

request restriction of processing ​of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data’s accuracy;

where our use of the data is unlawful but you do not want us to erase it;

where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;

you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

request the transfer ​of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;

o o o

o

● withdraw consent at any time ​where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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