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Privacy Policy

Thriftify Technologies Ltd.

Privacy Policy

5th November 2018

Background:

Thriftify Technologies Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site AND You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site or a Third Party when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Our Cookie Policy;

“Our Site” means this website, www.thriftify.ie

“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our” means Thriftify Technologies, a limited company registered in the Republic of Ireland, whose registered address is 35 Exchequer Street, Dublin 2.

2. Information About Us

Our Site, www.thriftify.ie is owned and operated by Thriftify Limited, a limited company registered in the Republic of Ireland, whose registered address is 35 Exchequer Street, Dublin 2.

Our data protection officer is Timur Negru who can be contacted at timur.negru@thriftify.ie

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see Our Cookie Policy), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

4.1 Name;

4.2 contact information such as email addresses and telephone numbers;

4.3 Postal and billing address;

4.4 Language;

4.5 IP address (automatically collected);

4.6 web browser type and version (automatically collected);

4.7 operating system (automatically collected);

4.8 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

4.9 gender and age group – on an anonymised level.

5. How Do We Use Your Data?

5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2 We use your data to provide the best possible products and customer service to you. This includes:

5.2.1 Providing and managing your Account;

5.2.2 Providing and managing your access to Our Site;

5.2.3 Personalising and tailoring your experience on Our Site;

5.2.4 Supplying Our products to you;

5.2.5 Personalising and tailoring Our products for you;

5.2.6 Responding to communications from you;

5.2.7 Supplying you with e.g. newsletters, alerts, discounts, new launches, etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking on the ‘unsubscribe’ button within the email confirmation you receive when signed up or you can also email us at any point at info@thriftify.ie;

5.2.8 Market research;

5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

5.2.10 To provide you with tailored and bespoke marketing offers based on your experience on our site or third parties

5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. We will never communicate with you unless there is something newsworthy to share.

5.5 Advertisers whose content appears on Our Site or third parties may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed in Our Cookie Policy. You can control and limit your data used in this way by adjusting your web browser’s privacy settings or by disabling third party cookies. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.

5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) you have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6. How and Where Do We Store Your Data?

6.1 We only keep your data for as long as We need to in order to use it as described above in section 5. In any event, We will conduct an annual review to ascertain whether we need to keep your data. For any of the customer data gathered as stated in point 4, We will keep it for as long as 6 years in accordance with the requirements for businesses established in Ireland, England and Wales.

6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

6.4 Steps We take to secure and protect your data include:

6.4.1 We store any personal data on online platforms such as Google Drive, One Drive, Dropbox. All of them are password protected and access to them is granted strictly to perform such activities as those listed in point 5. No personal data is stored in physical hard drives. When hard copies are needed e.g. printed invoices for tax record purposes, they are destroyed securely as soon as they are no longer deemed necessary.

6.4.2 All necessary online platforms such as Magento, Mailchimp, Hosting companies, Amazon we use to operate our Site and provide our products to you are password protected with a two-step login where necessary.

6.4.3 Everyone in contact with personal data such as third-party suppliers e.g. charity shops, couriers, freelancers, employees, directors, etc are trained and agreements are signed to make sure they follow all the guidelines set in this privacy policy.

6.4.4 Any emails exchanged with personal data e.g. with couriers, freelancers are stored online within the email provider network e.g. Google.

6.4.5 Backups are made daily and all copies are stored automatically in the cloud using any one of the providers mentioned in point 6.4.1

6.4.6 Any laptops or hardware used to access any of the above applications, services, websites are password protected and connected only to private networks

6.4.7 We do not store any credit/debit card information as we use Stripe and Paypal as our payment processors so all the financial information that you provide to carry out your purchase is stored on their platforms following their own privacy policies

6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

6.6 All the above operators have taken steps to become GDPR compliant and we have signed data processor agreements where necessary.

7. Do We Share Your Data?

7.1 We may contract with third parties to supply products to you on Our behalf. These may include payment processing such as Paypal and Stripe, delivery of goods such as Royal Mail, Fastway, express couriers, search engine facilities, advertising, and marketing platforms. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What Happens If Our Business Changes Hands?

8.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business that is being transferred, be transferred along under the terms of this Privacy Policy.

8.2 If we intend to handle your personal information for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your personal information for the new purposes.

9. How Can You Control Your Data?

9.1 When you submit information via Our Site, you will be given options to restrict Our use of your data (for further information about this please refer to Our Cookie Policy). Every time that you share data with us, you will be clear how that information will be used for so you can make an informed decision about giving us consent. You will be asked to double opt-in when you subscribe to our lists to make sure your consent is clear to Us. You can unsubscribe at any point in time using the links provided in Our emails or in the confirmation email you receive when you first signed up.

10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data under the ‘strictly necessary’ cookies e.g. location to see the correct currency for the products and catalogue availability.

10.2 You may restrict your internet browser’s use of Cookies or when you first visit Our Site by clicking on Our ‘cookie banner’.

10.3 You may withdraw your consent for Us to use your personal data as set out in section 5 at any time by contacting Us using the details set out in section 14, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

11. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). You can submit such a request by contacting Us at info@thriftify.ie

12. Summary of Your Rights under GDPR

Under the GDPR, you have:

12.1 the right to request access to, deletion of or correction of, your personal data held by Us;

12.2 the right to complain to a supervisory authority;

12.3 be informed of what data processing is taking place;

12.4 the right to restrict processing;

12.5 the right to data portability;

12.6 object to processing of your personal data;

12.7 rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

13. Automated Decision-Making and Profiling

13.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

13.2 The right described in section 13.1 does not apply in the following circumstances:

a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;

b) The decision is authorised by law; or

c) You have given you explicit consent.

13.3 Where We use your personal data for profiling purposes, we will use data processors that are GDPR compliant and we will make sure that we will take all steps to anonymise any ties to personal data.

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@thriftify.ie or by post at 35 Exchequer Street, Dublin 2. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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