Introduction

We are committed to protecting your personal information, and here is an outline of our policy, which covers our website and other online areas owned or operated by us, including, but not limited to, associated services, applications and platforms (collectively the “Site”)

Collection Pot respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use the Site (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1              Important information and who we are

1.1            Purpose of this privacy policy

This privacy policy aims to give you information on how Collection Pot collects and processes your personal data through your use of the Site, including any data you may provide through the Site.

The Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2           Controller

Collection Pot is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity: Collection Pot Limited

Email address: hello@collectionpot.com

Telephone number: +44 (0)33 0175 5428

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (prelive.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3           Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 24th December 2020 .Historic versions can be obtained by contacting us.

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.

1.4           Third-party links

The Site 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 Site, we encourage you to read the privacy policy of every website you visit.

2              The data we collect about you

2.1 Types of 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 as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes information about any recipients of products you wish us to deliver products to and other details of products 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 the Site.

Profile Data includes your username and password, purchases or orders made by you.

Usage Data includes information about how you use the Site, 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). 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 website 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 privacy policy.

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 (Special Categories of Personal Data). Nor do we collect any information about criminal convictions and offences.

We will not share any of your personal data with other users of Collection Pot unless we have your specific permission.

2.2          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 products 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.

2.3          Payments and transactions

Your card details are not recorded or stored in our database. If you are required to provide your bank account or payment card details this will be through a secure payment page hosted by our payments processor.

3             How is your personal data collected?

We collect personal information about you when you access the Site, register with us, contact us, send us feedback, purchase products or services via the Site, post material to the Site, complete customer surveys or register for newsletters.

We use different methods to collect data from and about you including through:

(a)         Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(i)           create an account on the Site;

(ii)          request marketing to be sent to you;

(iii)         give us feedback; or

(iv)         contact us.

(b)         Automated technologies or interactions. As you interact with the Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see clause 4.6 below for further details.

4             How we use your personal data

4.1           Circumstances in which we use your personal data

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:

(a)         Where we need to perform the contract we are about to enter into or have entered into with you.

(b)         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.

(c)         Where you have given us clear consent for us to process your personal information for a specific purpose.

(d)         Where we need to comply with a legal obligation.

The Glossary contains more information about the types of lawful basis that we will rely on to process your personal data.

You have the right to withdraw consent to marketing at any time by contacting us.

4.2          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 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/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a user so that you can take advantage of the Site’s features(a) Identity(b) ContactPerformance of a contract with you
To process donations and claim Gift Aid, if applicable(a) Identity(b) ContactPerformance of a contract with you
To process and deliver your order for a product(a) Identity(b) Contact(c) Transaction(d) Marketing and CommunicationsPerformance of a contract with you
To manage our relationship with you which may include:(a) Notifying you about changes to our terms or privacy policy(b) Sending you newsletters and keeping you informed of new products and seasonal offers.(c) Sending you emails in relation to your use of our services or products, reminders of special events and alerts relating to orders.(d) Sending you communications we are required to provide you by law(a) Identity(b) Contact(c) Profile(d) Marketing and Communications (a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how users use our products/services)

4.3          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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used our services or ordered products from the Site and have not opted out of receiving that marketing.

4.4          Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.5          Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Please allow three working days for your opt out to be processed.

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.

4.6          Cookies

In order to improve the service offered to you, we may use a ‘cookie’. A ‘cookie’ is a small data file which is placed on your computer or other device by the Site and which collects certain data about your activity on the Site. The primary purpose of this use of cookies is to ensure the process of personalising our service is user-friendly and consistent throughout a session.

Under the law we can store cookies on your device if they are strictly necessary for the operation of the Site. For all other types of cookies we need your permission. We may use different types of cookies, all of which are listed in the cookies pop-up box on the Site. These may include cookies that allow us to see how you have come to the Site and the webpages that you visit on the Site, and cookies that enable us to recognise you when you return to the Site.

We may link to third party websites from the Site, or embed third party content on our pages. If you access this content, those third party websites may also place cookies on your device.

You can withdraw your permission at any time by updating your cookie preferences. You can set your browser 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 the Site may become inaccessible or not function properly.

You can block or delete cookies that are already placed on your device by following the instructions set out at prelive.allaboutcookies.org.

4.7 Google reCAPTCHA

We have implemented reCAPTCHA v3 on our Site which is subject to the Google Privacy Policy and Terms of Use. When you use our Site, reCAPTCHA v3 collects some of your personal information to determine that you are human, and not a bot, to prevent spam.

The reCAPTCHA API works by checking if there is a Google cookie on your computer, and then adds a reCAPTCHA cookie to your browser to take a snapshot of your browser window at that moment in time. It also gathers certain information, including cookies placed by Google over the last 6 months, time you spend on the Site, the language your browser is set to, the date, and how many mouse clicks you have made on the screen. This information, collected in connection with the use of reCAPTCHA, is sent to Google and will be used for improving reCAPTCHA and for general security purposes and will not be used for personalised advertising by Google.

4.8          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.

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.

5             Disclosures of your personal data

We will not share any personal data with third parties unless required to do so by law.

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.

6             International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

7              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 use Secure Socket Layers (SSL), the most advanced security system available. All of the personal information you enter, including your name and address, is encrypted by secure server software before it is safely transmitted across the internet. Our Customer Service Team has access to this information.

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.

8             Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being users for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights (clause 9) below for further information.

9             Your legal rights

9.1 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, details of which can be found in the Glossary:

(a)         Request access to your personal data.

(b)         Request correction of your personal data.

(c)         Request erasure of your personal data.

(d)         Object to processing of your personal data.

(e)         Request restriction of processing your personal data.

(f)           Request transfer of your personal data.

(g)         Right to withdraw consent.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.

If you wish to exercise any of the rights set out above, please contact us.

9.2          No fee usually required

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.

9.3          What we may need from you

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.

9.4          Time limit to respond

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.

10            Glossary

10.1          Lawful basis

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 contacting us

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to

10.2         Your legal rights

You have the right to:

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.

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. 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.

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:

(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.

(d)         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.