Privacy Policy

Privacy Policy (Last Updated: 30.10.2018)

This website is brought to you by Snapsaver Ltd of 65 Village Heights, Gateshead, Tyne & Wear, NE8 1PW (we, our or us).  We are committed to protecting and respecting your privacy. We are the data controller i.e. the company who is responsible for, and controls the processing of, your personal data.

This policy (together with our terms of use for our website https://snapsaver.co.uk/terms-and-conditions and any other documents referred to on it) 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. 

Please note, if you download and/or use our mobile app there are separate terms and conditions of use and a specific privacy policy which details how your information is used. 

This privacy policy is for visitors to our website and our partnering businesses.

Click on one of the links below to jump to the listed section.

Changes to our privacy policy

Information we may collect from you

How is your personal data collected?

Purposes for which we will use your personal data

Disclosure of your personal data

Cookies

International Transfers

Security

Data Retention

Third Party Links

Your Rights

Contact

1. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

2. Information we may collect from 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 follows: 

  • Identity Data includes first name and last name
  • Contact Data includes home address, email address and telephone numbers.
  • 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. 
  • Usage Data includes information about how you use our website. 
  • 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 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 the 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, for example our business sign-up form, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
  1. join our waiting list;
  2. become a partnering business;
  3. subscribe to our service or publications; 
  4. request marketing to be sent to you;
  5. enter a competition, promotion or survey; or
  6. 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 section on Cookies for further details.
  • Third parties or publicly available sources. We may receive personal data about you from third parties, in particular, Technical Data from analytics providers such as Google based outside the EU.

Informing us of 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.

Information about other people: If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his or her personal data and receive on his/her behalf any data protection notices.

Monitoring: We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance. 

4. 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 add you to our waiting list / sign up for Snapsaver (a) Identity 

(b) Contact

Performance of a contract with you
To work with you as a partnering business (a) Identity

(b) Contact

Performance of a contract with you
If you are a partnering business, to send you updates about Snapsaver and the service we offer (a) Identity

(b) Contact

(c) Marketing and Communications

Legitimate business interest in keeping you updated on the service we currently provide to you
To send you marketing (a) Identity

(b) Contact

(c) Marketing and Communications

Consent
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) 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 customers use our services)

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

(b) Contact 

(c) Usage 

(d) Marketing and Communications

(a) Performance of a contract with you 

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

To administer and protect our business and this website (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 use data analytics to improve our website, services, marketing, customer relationships and experiences (a) Technical 

(b) Usage 

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

Information we receive from other sources: We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of your personal data

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may share your information with selected third parties including:

  • suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our website.

We may share information with specific third parties, such as our partnering businesses who offer discounts on our app.

Our partnering businesses change constantly, and often any information we share with them will be 

anonymised.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if all, or substantially all, of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use https://snapsaver.co.uk/terms-and-conditions and other agreements; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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. Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. They are saved to your computer’s hard drive that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience.

We use cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer and/or device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer and/or device.

This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information http://www.google.com/privacy.html.

A full list of the cookies we use are below:

_ga: Google Analytics cookie that assigns each visitor with a unique number and tracks their session data. Installed upon loading the site and expires after 2 years.

_gid: Google Analytics cookie that tracks pages visited by that visitor and is installed upon loading site. There is no expiration period.

_gat: Google Analytics cookie that throttles data from high traffic sites, and is installed upon loading the site. This cookie expires after ten minutes.

viewed_cookie_policy: This cookie is installed once you have accepted our policy, to ensure you are not asked to accept cookies again. There is no expiration period set on this cookie. 

There is a notice on our home page which describes how we use cookies and which also provides a link to our Privacy Policy. If you use this website after this notification has been displayed to you we will assume that you consent to our use of cookies for the purposes described in this Privacy Policy.

We work with a third party supplier who uses the following cookies on our landing page:

_ksid: A unique identifier given to users which is used to detect fraud across campaigns. 

kol_ab_<number>: this sets what version of the test the visitor saw so they always see that version of this test. 

kol_bounce.bounce.<number>: stores if this user has seen an exit intent widget so it isn’t shown every time. 

kola.<number>: A unique ID for every user used for analytics and fraud detection. This carries across browser sessions.

kola.<number>.session: A unique ID for a user that is unique for that session used for fraud detection and analytics.

kola.<number>.cid: Once someone signs up for a campaign we keep this cookie so that we can pull their contest points and status when they come back. 

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org

7. International Transfers

We do not transfer your personal data outside the European Economic Area (EEA), however Facebook and Google are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Both Facebook and Google are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

8. 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. However, the transmission of information via the internet is not completely secure. 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.

9. Data Retention

By law we have to keep basic information about our customers (including Contact/ Identity) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.

10. Third Party Links

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

11. Your 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; 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Complain 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.

12. Contact

Questions, comments and requests regarding this privacy policy are welcomed, please either contact us by: