What information do we need and why?
We need your name, age, gender and contact details, and to collect your location information, to provide the Services. We also gather information relating to you and your online behavior less directly by:
- tracking you online and across devices, including using cookies (in accordance with our cookies policy). We use this to market our products and services (and that of Retailers) where we have appropriate consents to do so and to prevent the use of our app/website for fraudulent transactions;
- combining data you provide with other data, in particular, product and transaction data from Retailer systems. We use this to create accurate customer profile based on interests and behavior on the platform
- using algorithms, which analyse data about you from social media, location data and access to Retailers’ websites. We use this to create profiles related to your shopping habits and, where we have appropriate consents from you to do so, to offer you products and services that you may be interested in. We may also anonymise your data and aggregate it with other users’ data (so that you could not be identified from this information and it is no longer personal data relating to you) and provide data analytic services to certain retailers with whom we have contractual relationships (Retailers).
We are processing your information:
- to be able to provide the Services
- as this is necessary for our performance of the Terms
- as this is necessary in pursuit of our legitimate interests in offering, developing and marketing the Services. We have balanced our legitimate interests with any potential risks to your data protection rights consider than these are outweighed by the significant benefits in being able to provide the Services to you and other users, improve checkout times when you and others purchase from Retailers and to improve our Services.
Who do we share your information with?
We may share your personal information with:
- Retailers for the purposes of carrying out your transactions and performing our Services
- Our IT service and infrastructure providers that we use as part of our app and website and IT storage solutions. Licenses belonging to all 3rd party software and infrastructure providers available upon request. Please email firstname.lastname@example.org.
- Any other third parties as required by law or for the purposes of crime (including fraud), to prevent or investigate breaches of, or to enforce, our Terms, to respond to or investigate security vulnerabilities, or to respond to emergencies, and to protect the rights of third parties.
- Any group companies or companies that may merge with or acquire us. If we were to reorganize or restructure our business due to financial difficulties, it is possible that your data may be considered a saleable asset and may be sold or transferred to third parties.
Use Of Your Information
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so. Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:
- to enable us to provide you with access to the relevant parts of the Sites;
- to supply the services you have requested;
- to enable us to collect payment from you; and
- to contact you where necessary concerning our services, such as to resolve issues you may have with your order.
We also process your data where we have a justifiable reason for doing so— for example personalisation of our service, including processing data to make it easier and faster for you to use our service. We have listed these reasons below:
- to improve the effectiveness and quality of service that our customers can expect from us in the future;
- to tailor content that we display to you;
- to enable our customer support team to help you with any inquiries or complaints in the most efficient way possible;
- to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Sites or our services, including letting you know that our services are operating in a new area, where you have asked us to do so;
- to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;
- to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Q-Zero.io LTD., or others (including to prevent fraud).
We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to present you with products that we think you will prefer, or to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see ‘Your Rights’ section below for more information. Where we rely on legitimate interest as a basis for processing your personal information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests. You can find out more information about these balancing tests by contacting us using the details above. Where we are under a legal obligation to do so we may use your information to:
- create a record of your order(s);
- comply with any legal obligation or regulatory requirement to which we are subject.
Will we transfer your personal data outside the UK?
We may transfer your personal information outside of the UK and the European Economic Area (EEA) to our IT providers and other suppliers. When transferring your personal information outside of the UK or the EEA, we will (and will ensure that service providers acting on our behalf agree to) protect it from improper use or disclosure and ensure the same levels of protection are in place as are applied within the UK and the EEA.
How long will we keep it?
We keep your personal information for the period required to perform the Services and then for 26 months following your termination of your relationship with us by deleting your profile on our app or website. Sometimes we de-identify your information so it can’t be attributed to you individually and use this data for data analytics and product development purposes. Otherwise, we securely erase your information once no longer needed.
You have the following rights regarding your information:
The right to be informed
The right of access
The right to rectification
You’re entitled to have your information corrected if it’s inaccurate or incomplete.
The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. Eg, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to object
You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent).
Rights in relation to automated decision making and profiling
We use technology to build profiles about you and may automatically approve or deny applications based on pre-determined factors related to your ability to meet your financial commitments in the case that you utilize a payment method which requires us to do so, and for you this means we may make certain assumptions about products you may be interested in and use this to send you more tailored marketing communications. The profile about you will also contain information regarding your purchase in the stores and your conduct when purchasing, in which case if the retailer deems you to be an risky shopper in regards to theft, we may need to disable your profile and restrict your use of the Service. We will usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing information for:
- baseless or excessive/repeated requests
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from the time we receive your request, but if the request would take longer than that to deal with, we will let you know.Making a complaint
If you are unhappy with how we’ve handled your information or you would like to exercise your rights, contact us here: Q-zero.io Ltd. Sandyford Business District, Sandyford D18 Ireland, email@example.com.