Privacy Notice BagFreeStuff.co.uk
Uneek Projects, trading as Bag Free Stuff (“we”, “our”, “us”) is committed to protecting and respecting your privacy. We are the data controller for the purposes of the General Data Protection Regulation (“GDPR”) and can be contacted here with the words “FAO: the Legal Department” at the start of the message or via the contact details at the end of this notice.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
What personal data we collect
We may collect and process the following types and categories of personal data about you:
- Contact information: name, postal address, email address, telephone numbers, username and associated correspondence between us.
- Demographic information: birth date, age, gender, postal code.
- Other identification information: information about your computer or mobile device, including your device identifier or other unique identifier (e.g. Android advertising ID or Apple IDFA), IP address, operating system and browser type.
- Preferences & Interests information: the types of offers and retailers/brands that interest you, information collected from social media interactions (such as via Facebook Connect).
- Transactional information: details of your visits to and use of our site www.bagfreestuff.co.uk (the “Website”) or our mobile application (the “App”) or emails that we send you (the “Emails”), including the offers you view and use, rewards you redeem, including receipts and other data you submit as part of the reward, traffic data and other communication data, the resources that you access, the transactions you make.
- Location information: includes information relating to the latitude and longitude of your device and the time and date the location information was recorded, your location relative to nearby retailers/brands or your presence within a geofence.
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.
The Website and App are not intended for children and we do not knowingly collect personal data relating to children.
How we collect personal data
We collect information about you in the following ways:
- Directly from you by email, phone, the Website, App or otherwise:
- if you submit forms on the Website or App.
- if you share a code or other promotion.
- if you contact us for any reason.
- if you enter one of our competitions.
- if you complete our surveys.
- if you otherwise interact with our services.
- Automatically as you interact with the Website, App and Emails by using cookies, tags and similar automatic data collection technologies.
- Automatically from location data transmitted by your mobile device. Please note mobile apps may collect this type of information even when they are not open. Please see the “Your rights and choices” section as to how you can limit or prevent the location information we may collect.
You can read about your choices in respect of these, including how you can opt out of receiving targeted advertising from many providers below in the “Your rights and choices” section.
How we use 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 it is necessary for our legitimate interests in conducting and managing our business including to enable us to provide you with best service and 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. 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 using the details below.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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 direct marketing communications to you via email. You have the right to withdraw consent to marketing email at any time as set out in the “Direct mailings and unsubscribing” section.
We use information held about you in the following ways:
- to ensure that content from our service is presented in the most effective manner for you and your device.
- to provide you with information, products or services that you request from us or which we feel may interest you.
- to carry out our obligations arising from any contracts entered into between you and us.
- to allow you to participate in competitions and interactive features of our service.
- to notify you about changes to our service.
- to report aggregate information to our business users. This is statistical data about our users' actions and patterns.
- to estimate our audience size and usage pattern.
- to store information about your preferences, and so allow us to customise our service according to your individual interests.
- to recognise you when you return to our Website or App.
- to gain understanding and insights about the nature of our audience and how they interact with our products and services, including A/B testing.
- to detect and prevent potential fraudulent or other activity in breach of our terms and conditions.
- to log when you have arrived at and / or leave a location (for example, a shopping centre, a high street or an airport).
- to provide location based services to you (for example, providing offers for retailers/brands nearby or other promotions relevant to your location).
Third parties collecting your data through cookies or other similar technologies referred to above may use the information to provide you with interest-based (behavioural) advertising or other targeted content.
Disclosure of personal data
We may share your personal data with the third parties set out below for the purposes set out in this privacy notice:
- Members of our group, which means our subsidiaries, our parent company (Uneek Projects) and its subsidiaries, as defined in section 1159 of the Companies Act 2006, and its holding companies.
- External third parties such as:
- Service providers who provide IT and system administration services (Google, Inc), email service providers (Salesforce, Inc.) customer services (Zendesk, Inc.), location services (Gimbal, Inc., for example, is a service provider that enables certain geo-location features for our App and consequently, Gimbal, Inc. and its affiliates collect, store, and process, on our behalf, certain location information and related data).
- Affiliate networks to track sales originating from our service.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
- 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 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 your personal data for specified purposes and in accordance with our instructions.
A list of third parties and affiliates can be found here.
When personal data is transferred outside the EEA
Some of the third parties and group entities set out above to whom we may transfer your personal data are located outside the European Economic Area (“EEA”). Consequently, the personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only 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 European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we transfer your personal data to our parent company (“Uneek Projects”) which is located in the UK or 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 European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may also transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us using the details below if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We do not use your personal data for making any automated decisions that would have a significant impact on you.
How long personal data is kept
We routinely delete personal data in respect of users who have not interacted with the Website, App or Emails for more than 30 months and location data after 2 months from creation.
We delete such data at the next routine deletion following the relevant period, which will be within 90 days.
Direct mailings and unsubscribing
Where you have consented to receive marketing communications from us, we will send you emails containing our latest codes, deals and promotions that we feel may interest you.
You may withdraw your consent for marketing communications (i.e. unsubscribe) at any time using one of the following methods:
- Click the “Unsubscribe” link in a marketing communication email we send you.
- Use the “Contact Us” page indicating your request to have your data deleted.
- Email our support team at email@example.com
Please allow two working days for this instruction to take effect in all of our systems.
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.
Your rights and choices
You have the right to:
- 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 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.
- 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.
Location sharing; you can adjust the settings on your device to disable sharing of your location data. Please note that if you disable the sharing of location data, you may be unable to access some features of our services that are designed to be location based.
Advertising; you can also opt-out of being targeted by certain third party advertising companies by visiting the following IAB opt-out platform, Network Advertising Initiative opt-out platform, Digital Advertising Alliance platform. You can opt-out of advertising provided by the Tune Marketing Console here. Please note that if you disable the display of personalised ads from our advertising partners, you may continue to receive ads that are less relevant to your interests/browsing behaviour.
Analytics; you can opt out of Google Analytics when using the Website on some devices by installing a browser plugin available here.
Social Media; you can manage the sharing of certain personal data when you register with us through a social media platform or application, such as through Facebook Connect.
Contact and complaints
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.
Questions, comments and requests regarding this privacy notice are welcomed and may be addressed here with the words “FAO: the Legal Department” at the start of the message.
Legal, Bag Free Stuff UK
117 Greenway Business Centre
Changes to this Privacy Notice
Any changes we may make to our privacy notice in the future will be posted on this page. You can obtain a historic version of this notice by contacting us using the details above.
This privacy notice is version “2018-1” and was last updated on 1st June 2018.