This policy (together with our terms and conditions of use as set out at Wonderbly's Terms and Conditions page applies when you use our website wonderbly.com (the “Website”) or visit a site that uses our advertising technology. 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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the EU General Data Protection Regulation 2016/679 (GDPR), the data controller is Lostmy.name Limited (trading as Wonderbly, Reg Co.number 08305498 ) of 30-36 Pritchards Road, London E2 9AP, United Kingdom.
This 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.
DATA WE COLLECT ABOUT YOU
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:
1. Information you give us – You may give us information about you by filling out forms on the Website or by corresponding with us by email, phone or otherwise. This includes information you provide when you register to use the Website, place an order on our Website, provide us with details required for a particular product, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey and when you report a problem with our Website. The information you give us may include your name, billing address, delivery address, email address, phone number, age, date of birth, gender, photograph, username, password and other registration information, as well as the book recipient’s name, date of birth, age, gender and address. Each piece of information you give us may be used independently or in conjunction with other information you provide to us.
2. Information we collect about you and your device – Each time you visit the Website we may 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;
- b. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed, purchased or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
3. Information we collect about you via advertising – From time to time, we may place ads on third party sites (such as YouTube). When you view or otherwise interact with our ads, we and our partners may use various technologies (such as cookies) to collect and store information about you including cookie data & anonymised IDs for attribution & advertising purposes. We use these technologies to help us understand more about our customers and the effectiveness of our adverts.
4. Information we receive from other sources - We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also 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) and may receive information about you from them.
5. Location Information - We may also collect information about your location, such as the IP Address of the device you access our Website from.
6. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
7. We do not collect your financial information. This is collected and stored by third party payment processors.
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, where you do not provide suitable delivery instructions 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.
HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through;
Direct interactions. You may give us your Identity, Contact, Technical 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:
- 1. apply for our products or services;
- 2. create an account on our website or utilise the live chat function on our website;
- 3. subscribe to our service or publications;
- 4. request marketing to be sent to you;
- 5. make a telephone call to us and leave a message or request a call back;
- 6. enter a competition, promotion or survey;
- 7. react to marketing posts on our social media forums (including but not limited to our Facebook, Twitter, Instagram pages); or
- 8. give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
1. Profile Data, Usage Data, Marketing and Communication Data, and Aggregated Data from the following parties;
- a. analytics providers such as Google based outside the EU;
- b. advertising networks;
- c. search information providers;
- d. third party providers of technical, payment and delivery services;
- f. from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We use data held about you in the following ways;
1. to allow us to provide you with our books and related services
- a. Legal Basis - Performance of a contract with you
- a. Legal Basis - Legitimate Interest for you to interact with our website
- a. Legal Basis - Performance of a contract with you to fulfill the promotion and run the competition/prize
- a. Legal Basis - Performance of a contract with you to fulfill product/service
- a. Legal Basis - Legitimate Interest of ensuring customers are updated of any changes
- a. Legal Basis - Legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business)
- a. Legal Basis - 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).
- a.Legal Basis - Legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)
- a. Legal Basis - Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and inform our marketing strategy)
- a. Legal Basis - Legitimate Interest (of fulfilling customer requests of being updated on products and services
- a. Legal Basis - Legitimate Interest (of fulfilling customer requests of being updated on products and services
- legitimate interests (to develop our products/services and grow our business, and to improve our offering to you) and Performance of a contract (ensuring product is delivered)
MARKETING & OPTING OUT
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Where you have not previously bought from us but have registered your details with us (for example by entering a competition or signing up for a newsletter), we will only send you marketing communications if you opted into receiving marketing at the time and so given us your express consent. However, if you receive a service from us, we will still need to send occasion service-related messages.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 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.
You have the option to unsubscribe from our e-mails through a link at the bottom of every e-mail we send to you. If you personally want to update the details that you have registered with us, or would like to amend your subscription preferences or unsubscribe altogether, you can do this in the “My Account” section of our Site.
You have the option to unsubscribe from online push notifications through disallowing notifications in your browser.
WHERE YOUR DATA IS STORED
All data you provide to us is stored on our secure servers in the EU. Where necessary and for a purpose you have consented to, data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
We will only transfer your personal data to third parties in territories outside the EEA where such transfer is compliant with applicable laws and regulations. For your information, this includes circumstances where;
Your data is kept only for the time necessary to provide the service or product you request, or to fulfil the purpose outlined in this policy.
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. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.
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 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under GDPR in relation to your personal data. You have the right to;
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.
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.
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 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.
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.
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.
7. 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.
8. 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.
9. 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.
10. 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.
You can also exercise your rights at any time by contacting us at firstname.lastname@example.org.
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INFORMATION ABOUT THIS POLICY OR TO EXERCISE YOUR RIGHTS
Latest update: 27 November 2019