Come Round ("We") are committed to protecting and respecting your privacy.
This policy (together with our website terms https://comeround.com/misc/terms/ and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
1. What information do we collect from you?
We may process the following data about you:
1.1 Information you give us.
What personal data might you supply to us?
How and why we process your personal data:
Registration Information: Information you provide when you register to use our website, register to join one of our campaigns, participate in discussion boards or other social media functions on our site and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.
We will process this data so we can deal with your registration, or other communications or applications, or to address your query or concern. The reason we process this data is to ensure the proper administration of your registration and our business. In legal terms the basis on which we process this information is our “legitimate interest”. If you are communicating with us in relation to a campaign, we will also need to process this data in order to perform our contract with you.
Communication Data: If you communicate with us, we may process the information contained in your communication. This information may include your name and contact information, the content of your communication and any metadata our website generates where you communicate with us using the contact form available on our website.
We will process that information so we can correspond with you and keep records of such correspondence. The reason we are processing this data is to ensure the proper administration of our business (our legitimate interest).
Notification Data: Where you have joined one of our Campaigns (either as a Selected Participant or as a Guest – please see our Terms for details of what these terms mean), or where you subscribe to receive our email notifications and/or newsletters, we will process your data so that we can send such email notifications and/or newsletters to you. If you prefer not to receive such communications please contact us using the contact details below.
The legal basis for us processing this data is that you have consented to such processing
Account information: Information about you which relates to your, or your employer’s account with us. This information may include your name, your email address and your telephone and/or mobile number.
We will process this data to maintain your account with us, to provide our services to you, to communicate with you and to back up our database. The reason we process this data is to ensure the proper administration of your account and our business and, where you have entered into a contract with us, for the purposes of fulfilling our contract with you.
Regulatory Data: We may process your data if we need to do so in order to comply with our legal and/or regulatory obligations, so that we can protect the vital interests of you or another natural person.
The reason we will process such data is to protect the vital interests of you or another natural person.
1.2 Information we collect about you.
With regard to each of your visits to our website we will automatically collect the following information:
(a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. We will obtain this data through our analytics tracking system. We process this data so we can monitor and analyse how our website is used so we can improve our website and our services.;
(b) information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page. We process this data so we can monitor and analyse how our website is used so we can improve our website and our services
1.3 Information we receive from other sources.
This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We may receive personal data about you from these organisations. Those organisations will have their own privacy policies detailing how they process personal data.
A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies we use are “analytical” cookies; they allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us improve the way our website works, for example by ensuring users are finding what they are looking for easily. We also use “strictly necessary cookies”, these are cookies that are required for the operation of our website, they include, for example cookies that enable users to log in to secure areas of our website in order to acquire the services we provide. Finally we also use “functionality” cookies. Functionality cookies are used to recognise users when they return to a website. They enable the personalisation of content, the recognition of users and remember user preferences. For more details about the cookies we use on our website, please click here.
You can block cookies by activating a setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser setting to block all cookies (including essential cookies) you may not be able to access all or parts of our site and this may affect your use of our site.
3. When will we disclose your personal data to others?
3.1 Where you have registered with us to participate in a Campaign, we will share your personal information (being your name and your email address) with the companies and organisations who instruct us to carry out Campaigns on their behalf. It is important that you understand that where you are involved in a Campaign, whether as a Selected Participate or Guest, your personal information will be shared with the company or organisation who has instructed us to carry out the Campaign on their behalf, and this is one of the main purposes behind the running of such Campaigns.
3.2 We may need to share your personal information with certain selected third parties including:
(a) our business partners, suppliers and sub-contractors for the purpose of performing any contract we have with you or them, including for the purpose of facilitating campaigns we are running that you are involved with. The reason we need such information may include, for example, being able to match you to the right campaign and so we can ship products and other materials to you for use at an event relating to a campaign. If you wish to discuss our proposed uses of your personal information, please email us at email@example.com.
(b) analytics and search engine providers that assist us in the improvement and optimisation of our website.
3.3 We may need to share your personal information with members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. These terms are defined in section 1159 of the UK Companies Act 2006. We will only share such personal information where this is necessary for the purposes set out in this policy.
3.4 We will also disclose your personal information to third parties in the following circumstances:
(a) If we sell or buy any business or assets, in which case we may need to disclose certain personal data to the prospective seller or buyer of such business or assets.
(b) If all or most of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
(c) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce any legal agreement we have with you; or to protect our rights or property, or the safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. Where do we store your personal data?
We will always try to ensure that your personal data is processed within the European Economic Area. In some circumstances this will not be possible. In circumstances where it is necessary for us to transfer your personal outside the European Economic Area, we will only transfer such personal data to third parties where we have carried out due diligence on such third parties to ensure they will protect your personal data using similar standards and safeguards as we have. We will also have contractual provisions in place with such third parties to ensure your personal data is protected. Such contractual provisions will be based on the standard contractual clauses approved by the European Commission for the transfer of data outside the EEA or such other appropriate standards as are required from time to time by the European Commission or the UK Government. You consent to the transfer of your personal data outside of the EEA, as long as we comply with these requirements.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, and we will maintain appropriate technical and organisation measures to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5. Storage and deletion of personal data
(a) We will determine the period for which we need to retain your data, acting reasonably, and taking into consideration a number of factors such as your relationship with us, your engagement with us, and the fulfilment of contracts we have with you.
(b) We may need to retain your personal data where this is necessary to comply with our legal or regulatory obligations, or to protect the vital interest or the vital interests of another natural person.
6. 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. Sometimes this may mean you will need to prove proof of your identity before we can disclose information to you.
7. Your rights
7.1 Under data protection laws you have the following fundamental rights:
(a) The right to access the personal data we hold about you;
(b) The right to have your personal data corrected if there are errors or inaccuracies in it, or your personal data is incomplete;
(c) The right to restrict the processing we carry out in relation to your personal data;
(d) The right to object to the processing we carry out in relation to your personal data;
(e) The right to have the personal data we hold about you provided to you in a useable format;
(f) The right to complain to a supervisory authority (in the UK this is the Information Commissioner’s Office) about how and/or why we are processing your personal data;
(g) The right to tell us you no longer consent to us processing your personal data. In practice you will usually agree in advance to us using your personal data for marketing purposes and if you no longer wish us to use your personal data for marketing purposes, you can opt out of receiving such marketing messages at any time. You can do this either by unsubscribing from the marketing messages we send you, notifying us in writing at firstname.lastname@example.org.
7.2 You can ask us to provide you with details of any personal data we hold about you. You do not have to pay us a fee to access your personal data unless we believe your access request is unfounded, repetitive or excessive. In this case we may charge you a reasonable fee to access your personal data or we may decide not to comply with your request. We will notify you if this is the case. We will require you to provide appropriate evidence of your identity before we respond to your request. Typically this identification evidence will be a photocopy of your passport or photo driving licence, which a solicitor or bank has certified as being a true copy of the original and a copy of a recent utility bill detailing your current address.
7.3 Our website may, from time to time, contain links to and from the websites of our clients, partner networks, advertisers and affiliates. If you follow a link to any of these websites, these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7.4 If you think that any of the data we hold about you is incorrect or inaccurate, you can contact us to correct such data. Please contact us at email@example.com for these purposes.
9. Information about us
Our data protection officer contacted at firstname.lastname@example.org.
10. Any questions?
227 Kensington Church Street,
Or by email at: email@example.com
© 2018 Come Round Limited
May 2018 Version