Welcome to the PickFree Group privacy notice.
The PickFree Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice applies to information we collect about:
• Visitors to our websites;
• Visitors to our premises;
• Customers; and
This version was last updated on the date as shown at the end of this privacy notice, and historic versions are available on request.
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.
2. IMPORTANT INFORMATION AND WHO WE ARE
The PickFree Group is made up of different legal entities, details of which can be found here www.pickmefree .com.
This privacy notice is issued on behalf of the PickFree Group so when we mention “PickFree “, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data.
LoaferUp INC is the controller and responsible for this website.
2.2 Contact details
Our full details are:
Full name of legal entity: LoaferUp INC
Please mark FAO: Chief Privacy Manager
Email address: firstname.lastname@example.org
Postal address: 740. E. Campbell Rd. Suite 700, Richardson, TX 75081
Telephone number: 469-857-3197
3. THE DATA WE COLLECT ABOUT YOU
3.1 What is personal data?
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, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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 our websites.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• 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, or the number of customers purchasing certain products. 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.
4.HOW IS YOUR PERSONAL DATA COLLECTED AND USED?
(a) Visitors to our websites
When you visit our websites, we use third party service providers (including Google Analytics and Adjusts) to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the websites. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our websites.
You may decide to submit personal information to us through the website, for example when purchasing goods or services, signing up to a newsletter, filling in a survey or entering a competition. When we collect personal data in this way this policy sets out what we intend to do with it.
Our websites are not intended for children and we do not knowingly collect data relating to children.
(c) Search Engine
Search queries and results of searches on our website are logged anonymously to help us improve our website and search functionality. We do not collect any user-specific data.
(d) Security and performance
To maintain the security and performance of our websites we use a third party service which processes the IP address of visitors and other Technical Data.
This information is retained for a maximum period of 24 months.
(e) Social Media
We use various social media channels, including Wechat, Weibo, Facebook and Twitter and will process your personal information when you interact with us (for example by liking or sharing a post). We use this information to improve our services.
(f) Online accounts
When you set up an online account with us, we will request personal data from you in order to verify your identity and set up your account. This information will also be used when you interact with us through the websites.
We will keep this information for a period of 5 years from the date of your last log in to the service, unless you have purchased goods and/or services through our websites or opted in to marketing communications in which case such accounts will be kept active for so long as we keep such information in line with the rest of this policy.
4.2 Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
4.3 Direct interactions
We may collect personal information from our direct interactions with you. This may include through correspondence, attendance at meetings with you, or other direct interactions.
4.4 Data received from third parties
We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data analytics providers such as Google, Yandex and others based outside the EU;
• Contact Data from providers of technical services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral
• Registers based inside the EU.
4.5 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 a product or service you have with us but we will notify you if this is the case at the time.
5. HOW WILL YOUR DATA BE USED?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract 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 or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (our contact details are set out above).
6. 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 (our contact details are set out above) 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 register you as a new customer||• Identity
|• Performance of a contract with you.|
|To manage our relationship with you which will include:
Asking you to leave a review or take a survey
• Marketing and Communications
|• Performance of a contract with you.
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||• Identity
• Marketing and Communications
|• Performance of a contract with you
• Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and the Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||• Identity
|• 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)
• Necessary to comply with a legal obligation
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||• Identity
• Marketing and Communications
|• Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Platforms, products/services, marketing, customer relationships and experiences, we analyse audience acquisition, behaviour and conversions||• Technical
|• Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platforms updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||• Identity
|• Necessary for our legitimate interests (to develop our products/services and grow our business)|
7. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us (our contact details are set out above).
By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
8.1 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us and if you provided us with your details when you participate a competition or online campaign or registered for a promotion, in each case, you have not opted out of receiving that marketing.
8.2 Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. This will include other members of the PickFree Group.
8.3 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us (our contact details are set out above).
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
9. SERVICE DEVELOPMENT
We use Aggregated Data to develop our services and products, but we may from time to time use your personal data, including feedback, responses to polls and surveys and other information provided by you to improve our service. This may include using recordings of calls for training purposes, and we will tell you if this is likely to be the case. You can ask for the call to not be used in this manner.
We may also use personal information that you have provided (including your communications with us) to offer customer support and fix problems.
10. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (our contact details are set out above).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out above. These parties may be:
• Other members of the PickFree Group who provide us with services to enable us to operate our business. We may also share personal data so that we can improve the PickFree Group’s products and services as a whole.
• Third party service providers (acting as processors) who provide IT and system administration services and support.
• Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
12. INTERNATIONAL TRANSFERS
Other members of the PickFree Group and many of our external third parties suppliers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us (our contact details are set out above) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
13. DATA 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
14. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are summarised below:
14.1 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.
14.2 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.
14.3 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.
14.4 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 may object to our processing of your personal data. 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.
14.5 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.
14.6 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.
14.7 Withdraw consent at any time
Where we are relying on consent to process your personal data you may withdraw this consent at any time. 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
14.8 How to exercise your rights
If you wish to exercise any of the rights set out above, please do not hesitate to contact us (our contact details are set out above).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
14.9 Your right to complain to the relevant supervisory authority.
You have the right to make a complaint at any time to your relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us (our contact details are set out above) in the first instance.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contact us (our contact details are set out above).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.