We are committed to protecting your personal information and here is an outline of our policy, which covers our website www.collectionpot.com and other online areas owned or operated by us, including, but not limited to associated services, applications and platforms (collectively the “Site”)
1 Important information and who we are
The Site is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Gifted to You Limited
Email address: email@example.com
Telephone number: +44 (0)33 0175 5428
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.
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.
1.4 Third-party links
2 The data we collect about you
2.1 Types of personal data
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, maiden name, last name, username or similar identifier.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes information about any recipients of products you wish us to deliver products to and other details of products 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 the Site.
Profile Data includes your username and password, purchases or orders made by you.
Usage Data includes information about how you use the Site, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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 (Special Categories of Personal Data). Nor do we collect any information about criminal convictions and offences.
We will not share any of your personal data with other users of Collection Pot unless we have your specific permission.
2.2 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 products 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.
2.3 Payments and transactions
Your card details are not recorded or stored in our database. If you are required to provide your bank account or payment card details this will be through a secure payment page hosted by our payments processor.
3 How is your personal data collected?
We collect personal information about you when you access the Site, register with us, contact us, send us feedback, purchase products or services via the Site, post material to the Site, complete customer surveys or register for newsletters.
We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(i) create an account on the Site;
(ii) request marketing to be sent to you;
(iii) give us feedback; or
(iv) contact us.
(b) Automated technologies or interactions. As you interact with the Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see clause 4.6 below for further details.
4 How we use your personal data
4.1 Circumstances in which 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:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) 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.
(c) Where you have given us clear consent for us to process your personal information for a specific purpose.
(d) Where we need to comply with a legal obligation.
The Glossary contains more information about the types of lawful basis that we will rely on to process your personal data.
You have the right to withdraw consent to marketing at any time by contacting us.
4.2 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 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 user so that you can take advantage of the Site’s features||(a) Identity
|Performance of a contract with you|
|To process donations and claim Gift Aid, if applicable||(a) Identity
|Performance of a contract with you|
|To process and deliver your order for a product||(a) Identity
(d) Marketing and Communications
|Performance of a contract with you|
|To manage our relationship with you which may include:
(b) Sending you newsletters and keeping you informed of new products and seasonal offers.
(c) Sending you emails in relation to your use of our services or products, reminders of special events and alerts relating to orders.
(d) Sending you communications we are required to provide you by law
(d) Marketing and 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 users use our products/services)
4.3 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 or used our services or ordered products from the Site and have not opted out of receiving that marketing.
4.4 Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.5 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Please allow three working days for your opt out to be processed.
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.
Under the law we can store cookies on your device if they are strictly necessary for the operation of the Site. For all other types of cookies we need your permission. We may use different types of cookies, all of which are listed in the cookies pop-up box on the Site. These may include cookies that allow us to see how you have come to the Site and the webpages that you visit on the Site, and cookies that enable us to recognise you when you return to the Site.
We may link to third party websites from the Site, or embed third party content on our pages. If you access this content, those third party websites may also place cookies on your device.
You can block or delete cookies that are already placed on your device by following the instructions set out at www.allaboutcookies.org.
4.7 Google reCAPTCHA
The reCAPTCHA API works by checking if there is a Google cookie on your computer, and then adds a reCAPTCHA cookie to your browser to take a snapshot of your browser window at that moment in time. It also gathers certain information, including cookies placed by Google over the last 6 months, time you spend on the Site, the language your browser is set to, the date, and how many mouse clicks you have made on the screen. This information, collected in connection with the use of reCAPTCHA, is sent to Google and will be used for improving reCAPTCHA and for general security purposes and will not be used for personalised advertising by Google.
4.8 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 will not share any personal data with third parties unless required to do so by law.
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 (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. 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 use Secure Socket Layers (SSL), the most advanced security system available. All of the personal information you enter, including your name and address, is encrypted by secure server software before it is safely transmitted across the internet. Our Customer Service Team has access to this information.
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.
8 Data retention
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, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being users for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights (clause 9) below for further information.
9 Your legal rights
9.1 Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, details of which can be found in the Glossary:
(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
(d) Object to processing of your personal data.
(e) Request restriction of processing your personal data.
(f) Request transfer of your personal data.
(g) Right to withdraw consent.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
If you wish to exercise any of the rights set out above, please contact us.
9.2 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.
9.3 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.
9.4 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.
10.1 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
10.2 Your legal rights
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 (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:
(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.
(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.