YES Icon sent to the installation of the Membifi App for the purposes of being rewarded for transactions with partners of Membifi. NO I do not consent to the installation of the Membifi App.
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at firstname.lastname@example.org that will not affect the lawfulness of any processing carried out before you withdraw your consent.
YES I consent to processing of my Location Data (including details of my current location disclosed by [GPS technology OR [OTHER TECHNOLOGY] so that location-enabled Services are activated to improve the users’ experience of the App.
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
· Membifi, version 1, mobile application software (App) available on your mobile phone once you have downloaded the App onto your mobile telephone or handheld device (Device).
· Any of the services accessible through the App that are available on mobile applications.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
1.1 This Privacy and Cookies Policy provides information on how Membifi Ltd (“we”, “us”, our”) collects and processes your personal data when you use our mobile application or visit our website www.membifi.com1.2 We are committed to protecting your personal data and to complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018),the UK General Data Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation (together, Data Protection Laws).
1.4 Our mobile application and website are not intended for children and we do not knowingly collect data relating to children.
1.5 We keep this policy under regular review. It was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on our mobile application and our website. We will make reasonable efforts to bring any material changes to this policy to your attention. You may wish to check this policy before using our mobile application or website as any changes will be effective from the date that they are made.
2.1 Membifi Ltd, incorporated in England and Wales under company number 13544251 and with registered offices at Our registered office is at The Old Village Hall Kingston Lisle Business Centre, Kingston Lisle, Wantage, England, OX12 9QX, is the controller and responsible for your personal data.
2.2 If you have any concerns or would like further information about our use of data or this policy in general, you can contact us at: email@example.com
3.1 Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (that is anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity Data that includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
· Contact Data that includes [email address and telephone numbers].
· Financial Data that includes [bank account and payment card details] although Membifi can only access the four first and last digits of the PAN number. Other details are fully encrypted and tokenised.
· Transaction Data that includes [details about payments to and from you and other details of voucher sand rewards you have used with us].
· Technical Data that includes [your login data, your phone’s operating system, time zone setting and location, browser plug-in types and versions, operating system and platform, internet protocol (IP) address, browser type and version and other technology on the devices you use to access our services].
· Profile Data that includes [your username and password, vouchers and rewards used by you, details of group buying clubs you belong to as well as clubs you have access to, your interests, preferences, feedback and survey responses].
· Usage Data that 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].
3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific application feature. 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 policy.
3.4 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.
4.1 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 service you have with us but we will notify you if this is the case at the time.
4.2 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
5.1 We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· Create an account on our mobile application;
· Sign-up for our services on our website;
· Enter a competition, promotion or survey;
· Give us feedback; or
· Contact us.
· Automated technologies or interactions. As you interact with our mobile application or our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies [server logs] and other similar technologies.
· Technical Data from analytics providers such as Google based outside the UK.
· Transaction Data and Technical Data through our data service provider, Fidel Limited based in Republic of Ireland and the United Kingdom.
6.1 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. These are legal bases for processing your data under the Data Protection Laws:
· Contract: where we need to perform the contract we are about to enter into or have entered into with you.
· Legitimate interests: where processing is necessary for our legitimate interests (or those of a third party), expect where such interests are overridden by your interest or fundamental rights.
· Legal obligation: where we need to process your personal data to comply with a legal obligation.
· Consent: where you have given consent to the processing of your personal data for one or more specific purposes, for example to send 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.
7.1 We have set out in a table format below a description of all the ways we plan to use your personal data, and which of the legal bases we rely onto do so.
7.2 We may process your personal data for more than one legal bases depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal bases we are relying on to process your personal data where more than one ground has been set out in the table below.
8.1 When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes. In addition, where necessary, your personal data may be shared with:
· Third parties who provide products or services to us, including software development, user analytics, email services, payment processing (Stripe), user notification and feedback functionality, marketing companies who help us manage our communications with you;
· Third party legal advisors and regulatory authorities, where it is necessary to share your personal data for the purposes of us complying with applicable laws;
· Third party professional advisers including lawyers, bankers, auditors, and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services;
· If the company or business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the company or business to facilitate the process;
· HM Revenue and Customs, regulators, and other authorities based in the UK who require reporting of processing activities in certain circumstances;
· Fidel Limited, who provides the link between your payment cards and your Membifi account. Fidel only transfers and stores personal data on Membifi’s behalf in the Republic of Ireland and the United Kingdom. Fidel Limited has its registered office at 9th Floor, 107Cheapside, London, EC2V 6DN, UK; and
· Mix panel UK Limited who provide real time insight into how people interact with our website and store information only in the EU. Mix panel UK Limited has its registered offices at 8Rockleaze Avenue, Bristol, England, BS9 1NG.
8.2 We may also provide third parties with aggregated but anonymised information and analytics about our users. Before we do so we will make sure that it does not identify you.
8.3 In some cases, when we share personal data, it will involve the transfer of that personal data to countries outside the UK which have different data protection standards to those which apply in the UK. Where we transfer personal data outside the UK we will ensure that there are adequate safeguards to protect your privacy rights under Data Protection Law.
9.1 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.
9.2 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.
10.1 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being users for tax purposes.
10.2 In some circumstances you can ask us to delete your data: see ‘Your Rights’ section for further information.
10.3 In some circumstances we will 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.
11.1 We use the following categories of cookies and similar technologies on our website:
· Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features, and to keep the site secure. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
· Analytics cookies: These cookies collect information about how you use our website, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
11.2 When you visit our website for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
11.3 You can block existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to either change the settings on your browser or use the cookie manager tool on our website. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop our website from working properly.
11.4 To find out more about cookies please visitwww.allaboutcookies.org.
12.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights include: · Request access to your personal data (through 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.
· 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.
· 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. We may however 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.
· 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 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.
· 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:
· if you want us to establish the data's accuracy;
· where our use of the data is unlawful but you do not want us to erase it;
· 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
· where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· 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.
· Withdraw consent at any time where we are relying on consent to process your personal data. 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.
12.2 To exercise any of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. 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.
12.3 We try to respond to all legitimate requests within one month. Occasionally it could 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.
12.4 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 could refuse to comply with your request in these circumstances.
13.1 To discuss or enquire about our use of your personal data or anything under this policy, please contact us at: firstname.lastname@example.org.
13.2 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or visit their website: https://ico.org.uk/make-a-complaint )13.3 You have the right to make a complaint at any time to the ICO or other competent supervisory authority of an EU member state if you have downloaded the Membifi App outside the UK.