Sooper Digital Ltd

PRIVACY AND COOKIES NOTICE

Last updated: 5 October 2019

1. ABOUT THIS PRIVACY AND COOKIES NOTICE

   • The website www.sooperdigital.co.uk (the Site) is
     operated by Sooper Digital Ltd (“we”, “us”, “our”), a company
     incorporated in England and Wales under company number 11799943 . Our
     registered office is at Easthampstead Works, Bracknell, RG12 1BH.
   • We are committed to protecting your privacy and complying with our
     data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).
   • When you interact with us or use the Site, we act as the data
     controller of your personal data. This means that we are responsible for
     processing your personal data and deciding how to use it. This privacy
     and cookies notice explains the types of personal data we may collect
     about you when you interact with us, why we collect it, what we use it
     for and what rights you have over that data. Personal data is any
     information about an identifiable person. Processing is anything we do
     with your personal data, including using, storing, sharing and deleting
     it.
   • This notice was last updated on the date shown at the top. We may
     change this notice at any time by posting an updated version on the Site
     and will make reasonable efforts to bring any material changes to your
     attention. You may wish to check it before using the Site as any changes
     will be effective from the date that they are made.

1. CONTACT INFORMATION

   • If you have any concerns or would like further information about our
     use of data or this notice in general, you can contact Matthieu Sewell
     at Easthampstead Works, Bracknell, RG12 1BH.

1. WHAT INFORMATION DO WE COLLECT?

   • We collect, store and use the types of personal data set out in the table at the end of this notice.

1. HOW WILL WE USE YOUR PERSONAL DATA?

   • We will use your personal data for the purposes set out in the table at the end of this notice.

1. HOW DO WE SHARE YOUR PERSONAL DATA?

   • When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data:
     • with employees, contractors, consultants or advisers, To facilitate sales and general commercial purposes;
     • with parties who provide products or services to us, such as
       software development, user analytics, email services, payment
       processing, advertising, user notification and feedback functionality,
       data insight companies etc;
   • We may also provide third parties with aggregated but anonymised
     information and analytics about our customers. Before we do so we will
     make sure that it does not identify you.

1. USE OF COOKIES AND SIMILAR TECHNOLOGIES

   • We and our third-party service providers use cookies and similar
     technologies to collect information about, and relevant to, your usage
     of the Site. Cookies are small text files that are stored on your
     computer when you visit the Site. It is standard practice to use cookies
     to make your experience better when using a website.
   • We use the following categories of cookies and similar technologies on this Site:
     • Strictly necessary cookies: These cookies are
       essential to enable you to move around the Site and use its features.
       Without these cookies, services you have asked for (such as remembering
       your login details or the items you placed in your basket) cannot be
       provided.
     • Analytics cookies: These cookies collect
       information about how you use the Site, for instance which pages you go
       to most often, what searches you perform and if you get error messages
       from web pages. Information these cookies collect can be used to improve
       how the Site works.
     • Customization cookies: These cookies allow the Site
       to remember choices you make (such as your user name) and provide
       enhanced, more personal features. These cookies cannot track your
       browsing activity on other Sites.
     • Social media cookies: These cookies allow you to
       share your activity on the Site on social media such as Facebook and
       Twitter. These cookies are not within our control. Please refer to the
       privacy policies of the social networks in question for information
       regarding how their cookies work.
     • Targeting or advertising cookies: These cookies
       record your visit to the Site, the pages you have visited and the links
       you have followed. We use this information to make our Site and the
       advertising displayed on it more relevant to your interests. [We may
       also share this information with third parties for this purpose.
   • When you visit the Site for the first time (and periodically after
     that), we will request your consent to the setting of all cookies other
     than strictly necessary cookies.
   • You can delete existing cookies and disable some or all types of
     cookies in future if you wish. To disable some or all types of cookies,
     you will have to change the settings on your browser. If you change your
     mind, you can enable cookies again at any time. Disabling cookies on
     your browser may stop the Site from working properly.
   • To find out more about cookies please visit allaboutcookies.org.

1. THIRD PARTYLINKS

   • This Site contains links to other websites over which we have no
     control. We are not responsible for and do not review or endorse the
     privacy policies or practices of other Sites which you choose to access
     from this Site. We encourage you to review the privacy policies of those
     other Sites, so you can understand how they collect, use and share your
     personal information.

1. YOUR RIGHTS

   • We respect your rights to privacy and will respond to requests for
     access or control over information about you in accordance with Data
     Protection Law. We may require you to verify your identity before we
     take any action.
   • Depending on the reason we have your personal data, you have a right to:
     • access the personal information we hold about you (commonly known as subject access);
     • request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
     • request that we erase your personal information in some
       circumstances, or object to our processing it as detailed at paragraph
       8.5;
     • restrict how we use your personal information, in certain circumstances;
     • request that we provide you with copies of your personal information
       in a machine-readable format or transfer it across different services;
       and
     • where we have asked for your consent to process your data, to withdraw this consent.
   • These rights are limited in some situations under Data Protection
     Law – for example, where we can demonstrate that we are under a legal
     obligation to process your data.
   • If you wish to exercise any of these rights, please contact us using the details in paragraph 2
   • Your right to object

You have a right to object to our processing of your personal data
and ask us to stop doing so. If we are processing your personal data or
direct marketing purposes (which includes profiling to the extent that
it is related to such direct marketing) and you object to this, we will
stop processing your personal data immediately.

If our processing of your personal data is in the public interest or
pursuant to our legitimate interests and you object to this, we will
stop processing your personal data unless we have compelling reasons
which override your interests, or our use of your personal data is for
the establishment, exercise or defence of legal claims.

• We hope that we can satisfy any queries you may have about the way
  we process your data. However, if you have unresolved concerns you also
  have the right to complain to data protection authorities (in the UK,
  the Information Commissioner’s Office). You can call the ICO on 0303 123
  1113 or go to their website: https://ico.org.uk/make-a-complaint/).

9. DATA RETENTION

   • Your personal data will only be kept for as long as necessary for
     our purposes. Specific periods are set out in the table at the end of
     this notice.

9. DATA PROTECTION PRINCIPLES

   • We process your personal data in accordance with the following principles:
     • we process your personal data lawfully, fairly and in a transparent way;
     • we collect your personal data for specified, explicit and legitimate
       purposes; any further processing we do is compatible with the original
       purposes for which for which we collected it;
     • we only process personal data which is adequate, relevant and
       limited to what is necessary to achieve the purpose for which it is
       processed;
     • we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
     • we do not store personal data in a form which identifies you for any
       longer than is necessary for the purposes of processing; and
     • we process personal data securely and in a way that protects against
       unauthorised or unlawful processing, accidental loss, destruction or
       damage.
   • When we ask for your personal data we will tell you whether you are
     required by law or contract to provide it, and what will happen if you
     do not provide the data.
   • Any request for consent to the processing of your personal data will
     be made directly to you and will include information about why we
     require the personal data and what will be done with it.

9. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

   • We will only process personal data when we have a lawful basis for
     doing that processing. The table at the end of this notice sets out the
     lawful basis we rely on for each type of data we process.
   • We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:
     • Consent: You have given consent to the processing of your personal data for one or more specific purposes.
     • Contract: The processing is necessary for the
       performance of a contract with you or in order to take steps at your
       request before entering into a contract.
     • Legal obligation: We need to process your personal data to comply with a legal obligation.
     • Vital interests: The processing is necessary to protect the vital interests of you or another person.
     • Public interest: Processing is necessary for the
       performance of a task carried out in the public interest or in the
       exercise of some official authority.
     • Legitimate interests: Processing is necessary for
       the purposes of legitimate interests pursued by us or someone else,
       except where such interests are overridden by your interests or
       fundamental rights and freedoms requiring the protection of your
       personal data.

TABLE OF PERSONAL INFORMATION WE USE

The table below sets out detailed information about our purposes for
processing, the basis for processing and the retention period for the
personal data.

Category of personal data

Purpose of processing

Lawful basis for processing

Retention period

Name and contact details

To sed marketing and promotional infromation to you

Digital marketing services and solutions

Consent

365 days

Date of birth

To personalise marketing communications and validate user age
Compliance with legal obligations
365 days

Payment information

To take payment and give refunds
Performance of contract
365 days

Contact history
To provide customer service and support
Performance of contract
365 days

Purchase history

To provide customer service and support and handle returns

Performance of contract
365 days

Browser, device and Site usage information

To improve the Site Performance

Performance of contract
365 days

Information from linked accounts

To enable you to log into the Site simply without having to create a specific account
Performance of contract
Consent
365 days

Responses to surveys, competitions and promotions

To run the survey, competition or promotion
Performance of contract
Consent
365 days

Customer comments and product reviews

To improve our products and services
Performance of contract
Consent
365 days

Information generated in the course of the use of our products and services

For internal research and development purposes and To improve and test the features and functions of our Site
Consent
365 days

Information collected through cookies and similar technologies
To conduct and store site usage analytics, statistical and trend analysis and market research

Consent
365 days