INFORMATION WE COLLECT AND RECEIVE
“Personal information” is information that identifies you as an individual or any other information which constitutes personal information under any applicable law, such as your name, postal address, telephone number, email address, and payment details. We collect and receive personal information about you in the following ways:
Personal information you give us
This includes any Personal information that you provide to us directly:
- by filling in forms on our Platforms;
- when you enter a competition, promotion or complete a survey;
- by posting comments or content on our Platforms;
- when you purchase our products or services;
- when you contact us or we contact you and you provide information directly to us (e.g., in-person).
We need to collect personal information in order to provide the Platforms to you. If you do not provide the personal information requested, we may not be able to provide the Platforms.
The Personal information we collect or receive
Depending on how you access and use our Platforms, we may receive:
- log-in information, such as e-mail address, name and other contact information;
- information we infer about you based on your interaction with Platforms, products and services, such as social avatar;
- device information (for example the type of device you're using, how you access platforms, your browser or operating system and your Internet Protocol ("IP") address);
- social media account ID;
- other profile information as controlled by that service which you use to access our Platform or as authorized by you via your privacy settings at that service; and
- location information, such as country location.
Personal information from third party sources
We receive additional information about you that is publicly or commercially available from the sources set out below and combine that with the information which we have collected or received about you in other ways:
- our affiliates, in other words, other companies in our group;
- third party platforms, social networking services and software tools (like Facebook, Twitter, LinkedIn, Instagram, Google and Auth0) which you may use to register and log into certain of our services and to share things you find on our Platforms with your social network, or otherwise interact with us using these services; and
- our business partners.
HOW WE USE THE INFORMATION WE COLLECT AND RECEIVE
Legal basis for processing information about you
We will only use information about you when the law allows us to do so. Most commonly, we will use this personal information in the following circumstances:
- where we need to perform a contract that 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; or
- where we have your consent to do so.
We have set out below a description of the ways in which we use information about you, and the lawful justification that we rely upon when we do so. We may process your personal information for more than one lawful basis depending on the specific circumstances; where this is the case, you can contact us for further information on which lawful basis we are relying on when processing your personal information.
We use the personal information we collect and receive for the following general purposes:
- to provide you with information, products or services that you request from us, which is necessary in order to perform a contract we have in place with you, or when necessary for our legitimate interests (to provide effective services to you) or to comply with a legal obligation;
- to communicate with you, which is necessary in order to perform a contract we have in place with you, or when necessary for our legitimate interests (to provide effective services to you), or when you have consented;
- to be effective and relevant in the services we provide you, which is necessary in order to perform a contract we have in place with you or when necessary for our legitimate interests (to provide effective services to you);
- to identify you and to enable you to access to the Platforms and services, which is necessary in order to perform a contract we have in place with you, or when necessary for our legitimate interests (to provide effective services to you), or when you have consented;
- to provide, maintain and improve our services, including developing new features, which is necessary for our legitimate interests (to better understand our customers and services, to keep our services updated and relevant, to develop our business and to inform our marketing strategy);
- to perform internal operations and for internal record keeping purposes, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, and monitoring and analyzing usage and activity trends, which is necessary to comply with a legal obligation to which we are subject or for our legitimate interests (to define types of customers for our products and services, or to keep our services updated and relevant);
- to contact you about certain promotions or contests that we are running, which is necessary in order to perform a contract we have in place with you;
- to provide effective advertising. We engage in these activities with your consent or where we have a legitimate interest. Many of our Platforms are supported by advertising. We want to enhance our users’ experience by serving advertising that may be useful to them. Some of the ways we do this are by:
- showing you advertising based on your online activities, such as the websites and apps you use or the content you viewed, as well as data we have collected about you, data that you have provided to us, or data that we have received from third party sources;
- limiting the number of times you see the same advertising; and
- measuring the effectiveness of the advertising we serve.
- We also use or disclose personal information, as necessary or appropriate: (a) to comply with applicable law, including other laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities in other countries; (d) to enforce our Terms and Conditions available here; (e) to protect our operations; (f) to protect your and our rights, property or safety, and/or that of others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT AND RECEIVE
We don’t sell your personal information to third parties for their marketing purposes.
We share personal information with:
- our affiliates, in other words, other companies in our group;
- our business partners. We may share non-personally identifiable information with select business partners;
- other parties in response to legal process or when necessary to conduct or protect our legal rights;
- public and government authorities, including authorities outside your country of residence, where we receive requests from them;
- other parties in connection with certain business transactions. In the event that we restructure or sell any of our businesses or assets, we may disclose your personal information to the prospective buyer of such business or assets or other transacting party;
- our service providers. Companies that provide services to us, for example website hosting, data analysis, payment processing, information technology and related infrastructure provision or act on our behalf have access to information about you. These companies are limited in their ability to use personal information they receive in the course of providing services to us or you;
- third parties where you provide consent. For example, when you authorize a third party application or website to access your account. In some cases, third parties (often advertisers), wish to obtain information about you in order to promote their products to you, or for whatever other reason. We share personal information with third parties where you provide consent in the form of explicit opt-in. We will also ensure that your opt-in is explicit and that we provide a clear description of what data would be shared with the third party. Remember that once you have opted in to allow us to send your personal information to the third party, we cannot control what they do with your data; therefore, be sure to investigate their privacy policies before providing permission for us to share your personal information;
other parties that provide content, advertising services, or functionality on our Platforms. Such third parties include:
- advertising providers, which help us provide ads that are tailored to users' interests and understand how users respond to those ads;
- audience-measurement companies, which help us measure the overall usage of our Platforms and compare that usage to other online services; and
- third party platforms, social networking services and software tools (like Facebook, Twitter, LinkedIn, Instagram, Google and Auth0) that enable you to register and log into certain of our services and to share things you find on our Platforms with your social network. This is only applicable if you choose to connect with a third party platform, networking service or software tool; we may provide other registration and login methods.
Some of the content, advertising, and functionality on our Platforms may be provided by third parties that are not affiliated with us.
You have the right to ask us not to contact you for marketing purposes. You can exercise this right at any time by using any of the various “opt-out” options that we will always provide to you when we communicate with you. We won’t send you marketing messages if you tell us not to do so, but we will still need to send you service-related messages.
You can opt-out of getting marketing messages in the following ways:
- when we call you as part of a telemarketing campaign, you can tell us if you don’t want to receive any more marketing calls;
- when we email you, you can use the link in it to opt-out of marketing emails;
- when we text you, you can text back to tell us to stop further SMS marketing;
- change the cookie settings that we hold for you on our website so you don’t receive targeted advertising online.
- Under certain circumstances and subject to certain exemptions, you have rights under data protection laws, to request to access, update, correct, suppress, restrict or delete your personal data provided to us, object to the processing of your personal data, or request to receive an electronic copy of your personal data for purposes of transmitting it to another company (where the right to data portability is provided to you by applicable law).
- We may ask you for additional information to confirm your identity and for security purposes, before responding to a request you raise. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
- You can exercise your rights by contacting us using the details below in the ‘Contact’ section. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfill your request.
OUR COMMITMENT TO SECURITY
Although we cannot guarantee the security of the information collected and received, we do employ a number of safeguards intended to help mitigate the risk of unauthorized access or disclosure of your information. We will do our best to protect your personal information and we will use up to date technology that will help us to do this.
LINKS TO OTHER WEBSITES
Our Platforms may contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- the length of time for we have an on-going relationship with you and provide the Platforms to you (for example, for as long as you have an account with us or keep using the Platforms);
- whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
INTERNATIONAL USERS AND TRANSFERS
- We are based in and operate from the UK and, regardless of where you use or access our Platforms, your information will be transferred to and maintained on servers located in the UK (or elsewhere in the world). If you are a data subject located in South Africa, by providing your personal information to us or by using our websites you consent to the processing and transfer of your personal information in and to a country other than the country from where you may access our Platforms.
We might transfer your personal information to places outside the UK or European Economic Area (“EEA”), which may have data protection rules that are different from those in the UK or the EEA (as applicable). If that happens, we require our suppliers to apply the same security standards as when we process your information in the UK or EEA by ensuring at least one of the following safeguards is implemented:
- We transfer your personal data to countries that have been deemed by the UK government or the European Commission (as applicable) to provide an adequate level of protection for personal data. This applies in respect of any transfer of your personal data (i) from the UK to the EEA and (ii) from the EEA to non-EEA countries.
- For transfers from the UK or the EEA to countries not considered adequate (such as when we share personal data with third parties, we rely on adequate measures, such as standard contractual clauses, which give personal data the same protection it has in the UK and the EEA. You may obtain a copy of these measures by using the information in the ‘Contact’ section below.
THIRD PARTY PAYMENT SERVICE
You also have the right to report your concern to an appropriate regulatory authority, depending on where you have your habitual residence or place of work, or where an alleged infringement of applicable data protection law occurs. For the UK, this is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). For the EEA, a list of data protection authorities is available here. For South Africa, you can lodge a complaint with the Information Regulator at complaints.IR@justice.gov.za.