Privacy Policy
 

Introduction

Where the words "we", "us" or "our" are used in this document, they are all references to GLAD People Limited, a company incorporated in England and Wales (under company registration number 10883046) and whose registered office is at The Gate Business Center, Keppoch Street, Cardiff, United Kingdom, CF24 3JW.  

 

We treat your information very carefully and we have written this document to help you understand what information we collect, who has access to it and for what purposes.  

 

We summarise below:

  • the types of information about you that we might process;
  • how and why we process it;
  • who we share it with;
  • how long we process it for;
  • your rights in relation to the information we hold about you; and
  • what to do if you have any questions or complaints.

You can ask us to stop processing your information at any time by emailing us at info@gladpeople.co.uk (although, as some types of information processing and sharing are essential to the provision of our services or certain aspects of those services, if you do ask us to stop processing your information we may not be able to provide some of the services or continue to provide the services in the same way).  

 

We encourage you to read the remainder of this policy to understand more about how your information is used.

  1. How do we collect information about you?

We collect information about you when you access our website (including if you have signed up to our Insights mailing list), use our chatbot or services, and when you contact us.

We might also receive information about you from someone else (for instance, from your social media accounts but only where you have agreed that they can share your information).  We will let you know if this happens and we are not already processing information about you.

  1. What information do we collect?

2.1 We may process the following types of information about you:

(a) information that may be used to identify you. This might include your title, name, postcode, email address, mobile phone number, date of birth and any other data you use to use our services;

(b) third party sourced data. Information that you grant us permission to collect, and public information, from third party apps or websites such as, but not limited to social media sites;

(c) information about how you transact using our app or services. This might include the goods or services you purchase, the rewards and gifts you earn and redeem (and when and where you do so), the transaction ID, the price paid or discount given, the location and time of the transaction, and the outcome of that transaction.  It might also include information about prize draws and promotions you participate in;

(d) anonymised GLAD People ID. A unique customer identifier;

(e) your preferences. Information about your use of our chatbot and services including location or demographic data, language preferences, notification settings and stated preferences (e.g. “favouriting” a particular merchant);

(f) network, hardware and website. Information that we obtain from your device or browser when you connect to the website or use our app (such as IP address, operating system and device identifiers). This also includes the use of cookies which we may place on your browser or device to help collect this information, or improve your experience on our website. For more information on cookies, please see our policy on cookies and

(g) surveys. Information that you have opted to provide to us in response to customer research and satisfaction surveys.

 

 

  1. What do we use your information for?

3.1 We use your information:

(a) to provide our services. To do this we might use your information to identify you, information about your use of our apps and services, information about your preferences and information about your device and networks. This might include doing things like:

  • processing and managing your application for and use of our services and participation in any reward or offer programmes offered by our merchants;
  • processing transactions that you initiate using our services;
  • communicating with you about your orders or purchases, our services, your account with us and to provide support where you contact us;
  • communicating with you about any prize draw, reward or offer programmes you participate in using our services;
  • facilitating the negotiation of any merger, sale of company assets, financing, acquisition or divestiture of all or a portion of our business;
  • providing electronic receipts;

(b) to improve our services. To do this we might use information like your location and information about your use of our services. This might include doing things like:

  • measuring the performance of our app and services;
  • making sure you use the right version of the app for where you are (like prompting you to change the language or location settings);
  • conducting statistical analysis about how you and other users of our services make use of those services. We might do this to make improvements to our services or to develop new services, but we will not share statistical analyses about you individually with anyone else;
  • providing software updates so that they deliver improved features and functionality (to our services better) or fixing bugs in our software;
  • changing how we run our business, organise ourselves and deliver the services to you; and
  • personalising parts of the service to your tastes and preferences, including the places you like to shop and the goods you like to buy;

(c) to communicate with you about marketing or promotional campaigns or to send you our Insights (but only where you have told us you want to receive these communications and you have not told us to stop sending you messages). To do this we might use data for the means of identifying you and ensuring you are who you say you are, your preferences, your device and network and information about your use of our services.  This might include:

  • sending you Insights;
  • sending you messages about sales, promotions or prize draws offered by us or a merchant;
  • personalising parts of the service to your tastes and preferences, including the places you like to shop and the goods you like to buy; and
  • creating personalised promotions based on your purchasing preferences and behaviour;

(d) for business, regulatory and legal purposes, like:

  • obtaining and maintaining insurance policies;
  • dealing with any requests you make or content you submit;
  • getting in touch if we need to tell you about something, like a change to our policies or issues with our apps or services;
  • managing risk (for instance, by assessing payment and funding risks, identifying, preventing, detecting or tackling fraud, money laundering and other crime and carrying out regulatory checks); and
  • complying with any court order or applicable law, regulation or governmental request (e.g. tax authorities) and to protect our rights or property, or the security or integrity of our business or services.

 

  1. How do we protect your information?

4.1 We hold personal data about you with the assistance of third-party service providers. We use third party service providers to perform a number of functions on our behalf including to host our platform, to send messaging on our behalf, to provide support services to you (including to provide translations to and from the English language) and to process transactions for the purchase of goods and services.

4.2 Your personal data may also be processed outside the European Economic Area by our staff or the staff of our third party service providers. Such staff may be engaged in, among other things, the provision of your support services. However, we will transfer your personal data only to a country that the European Commission has decided is a country which ensures an adequate level of protection or if we have otherwise provided for other appropriate safeguards to legitimise such data transfers.

4.3 Whenever we share your personal data with third parties, we will take all reasonable steps to ensure that your privacy rights continue to be protected under the applicable data protection legislation. By sharing your personal data with us and interacting with the services, you consent to the storing, processing and/or transfer described in paragraphs 1 and 4.2 above.

4.4 If data is transferred to a country where appropriate safeguards need to be put in place, we would be happy to provide information pertaining to such safeguards on request. You can contact us for this information by emailing info@gladpeople.co.uk.

4.5 We take reasonable measures, including administrative, technical and physical safeguards, to protect your personal data from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.

4.6 We do not store customer card details.

 

  1. Who do we share your personal data with and why? 

5.1 Transfers to other data controllers

(a) Where you have registered using, a merchant branded version of our app, we may share information about you, your account and how you use the service and the merchant branded version of our app with the relevant merchant.

(b) We might also share your information with a merchant to investigate and resolve support issues you experience or where you notify us of a complaint about a merchant or the goods or services you purchase from them.

(c) The information we share might include:

  • information that can be used to identify you;
  • information about how you transact using our app or services;
  • detailed transaction data;
  • your preferences; and
  • where you have raised a support issue or notified us of a complaint about a merchant or the goods or services you purchase from them, the nature of the issue or complaint.

5.2 Third party sourced data. We do not share personal data received from third party sources other than as stated in paragraph 1(c) above.

5.3 Transaction data. We share transaction information with the merchants who are receiving payment or providing rewards and offers on that transaction. We do this so that the merchant can reconcile their point of sale data with our data and to allow them to analyse transactions. We only send this information with your Anonymised GLAD People ID – never your information that could be used to identify you.

5.4 Anonymised GLAD People ID:

5.5 Other uses. We may share your information with third parties, including law enforcement agencies for any of the following:

(a) to fulfil our obligations, or as required by applicable law or payment method rules;

(b) to assess financial and insurance risks, risk of fraud, sector risk and credit risk;

(c) in relation to any breach of data;

(d) to recover debt or in relation to your insolvency;

(e) to develop products, services and our systems;

(f) to detect, investigate and prevent fraud or other crime;

(g) to respond to requests from courts, law enforcement agencies and other governmental or regulatory authorities or agencies; and

(h) to protect our rights, privacy and property, and that of our customers.

5.9 We may also share your information with:

(a) our service providers. Service providers help us with things like payment processing, website hosting, data analysis, information technology and related infrastructure, customer services, email delivery and anti-fraud services. These third parties are authorised to use your information only as necessary to provide their services to us and we take appropriate steps to ensure that third parties protect your information; and

(b) third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We shall endeavour to ensure such third parties are bound by confidentiality obligations in relation to such information.

  1. How long do we process your information for? 

6.1 In most cases we will process your information only for as long as we need to in order to provide the services or until you close your account or ask us to stop processing your information.

6.2 You can ask us to stop processing your information or change the way in which we use it by:

(a) changing the settings in our app (to effect changes to things like your location settings, language settings, notification settings, access to your contacts list); or

(b) otherwise, by:

  • emailing info@gladpeople.co.uk; or
  • writing to us at Customer Support (Data Protection), GLAD People Limited, The Gate Business Center, Keppoch Street, Cardiff, United Kingdom, CF24 3JW

6.3 There are some exceptions to this, however. We may have other lawful grounds for processing your information (for example, to comply with our statutory or regulatory duties or the orders of a court).  For example, we might be required to retain your personal data for a longer period (usually up to six years after you close your account or tell us to stop but this may vary depending on the territory in which you use the service) in order to comply with applicable law, tax obligations or regulatory requirements.  This might apply to information about the transactions you make, when and where you make transactions and the information we hold about you for fraud and other crime prevention purposes.  If we do retain your information in this way, we will cease other forms of processing and we will continue to keep your information secure.

  1. Your rights 

7.1 You can request a copy of the personal data we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out. For further information, please contact us by emailing info@gladpeople.co.uk with the subject "Data subject access request".

7.2 You can correct, restrict our use of or ask us to delete your personal data at any time by emailing info@gladpeople.co.uk with the subject “Data subject change request”.

7.3 If you have any questions about this document or in relation to how we use your personal data, please contact us by:

(a) emailing info@gladpeople.co.uk; or

(b) writing to us at Customer Support (Data Protection), The Gate Business Center, Keppoch Street, Cardiff, United Kingdom, CF24 3JW 

  1. Complaints 

8.1 If you wish to make a complaint about how we process your information, please contact us by

(a) emailing info@gladpeople.co.uk; or

(b) writing to us at Customer Support (Data Protection), The Gate Business Center, Keppoch Street, Cardiff, United Kingdom, CF24 3JW

8.2 The Information Commissioner’s Office regulates data protection and privacy matters in the UK and you have the right to make a complaint to the Information Commissioner’s Office at any time about the way that we use your information. You can find more details at ico.org.uk however we should appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office.

 

  1. Updating our Privacy Notice 

9.1 We may update this Privacy Notice from time to time. When we do so, we will post the new version on our website and will ask you to accept the new version when you next use our app.

 

  1. Cookie 

10.1 You can set your browser (and some mobile device settings) to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our app and our services may become inaccessible or not function properly. For more information about the cookies we use, please see our policy on cookies.