Privacy and Data Policy
Last Updated: May 2018
1. INTRODUCTION AND GENERAL TERMS
Our website (the “Website”) is operated by Walloh Limited a company registered in England and Wales under Company Number 08925604 with its registered office at Flat 4, 7-9 Cross Street, London, N1 2BH United Kingdom ("Walloh", "we", "us" or "our").
This policy should be read together with our Website Terms & Conditions (which can be found here).
The Website may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
Information provided by you from social media sites
We will collect information if you choose to connect your Facebook profile with the Website which may include your:
- First and last names
- Facebook ID and username
- Location coordinates, post code and date when the location was stored; and
Contact information provided when you complete a purchase
If you decide to make a purchase, we will also need you to hold:
- Your name and billing address; and
- Details of transactions you have made with us and of the fulfilment of your orders
Information collected for the purposes of providing analytics
Our Online Services also uses website analytics, including Google Analytics, to evaluate and improve our Online Services, personalise your experience and to offer the best, most accessible service possible to all of our customers.
To find out more about Google Analytics and to learn how to opt out, please visit:
We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. When you use our Online Services, us and our service providers may collect data which includes the following, which will most likely be anonymised and aggregated before reporting back to us:
- number of visitors to our Online Services;
- pages visited while at the Online Services and time spent per page;
- page interaction information, such as scrolling, clicks and browsing methods;
- websites where visitors have come from and where they go afterwards;
- other technical information relating to end user device, such as IP address or browser plug-in;
- in the case of our chat bot, your last conversation with us.
- We process this information to understand how visitors use our Online Services and to compile statistical reports regarding that activity. This processing is crucial to the running of our online business. This information is not used to develop a personal profile of you.
3. WHY WE COLLECT INFORMATION ABOUT YOU
To provide our Online Service to you
We will use your Profile Information in order to provide our chat bot functionality to you and to enhance the service you receive. For example we will use your location and film preferences to suggest the most relevant events for you to attend.
To help fulfil your orders
We will process your Billing Information when entering into an agreement with you to provide our products (or the products of third parties) and to log and process your order in our system.
All financial transactions via our e-shop are handled directly by our payment service providers (Braintree). We only share that information as is necessary to conclude the transaction and will not share any personal information with these third-party providers, nor will we receive any of the financial information that you provide to them.
To improve our Online Service
We process Analytics to understand how visitors use our Online Services and to compile statistical reports regarding that activity. This processing is crucial to the running of our Online Services and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website and providing a better service and source of information to visitors. Where we use third party analytics services they will collect information on our behalf in accordance with our instructions. We have contracts in place to protect the confidentiality of your information with all of our third-party data analytics service providers.
If you ask to be added to our mailing list, we will keep you updated with information on our events and our services by email unless you would like to be removed from that list (in which case please let us know by writing by clicking unsubscribe at the bottom of each Newsletter).
4. DATA SHARING
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of Walloh, our customers, or others.
5. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you wish to opt-out from Google Analytics, you may use this add on for your browser: Google Analytics Opt-Out. You can also opt out of the collection of Profile Information by denying access to the Facebook chat bot plugin in your Facebook settings.
6. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.
To make a request, please let our Data Protection Officer know by sending an email to firstname.lastname@example.org.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
- you consented to our processing the personal data, and have withdrawn that consent;
- we no longer need to process that personal data for the reason it was collected;
- we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Walloh or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
- the personal data was unlawfully processed;
- you need the personal data to be deleted in order to comply with legal obligations;
- the personal data is processed in relation to the offer of a service to a child.
Obtain a machine readable copy of your personal data, which you can use with another service provider
- If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
- If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Make a complaint to a Supervisory Authority
- If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
- If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.
7. DATA RETENTION
We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as Walloh management or employees whose main role requires system access).
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
10. INTERNATIONAL DATA TRANSFERS
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers.
We may also transfer your personal data to our third-party service providers, some of which may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
Where we transfer your data outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to email@example.com.
All questions, comments or enquiries should be directed to firstname.lastname@example.org. We will endeavour to respond to any query or questions within two business days.
© 2018 Walloh Limited. All trade marks are the property of the relevant owners. All rights reserved.