Privacy Policy updated 7th Jan 2019
Policy Statement
Toople including its wholly-owned subsidiaries complies fully with the General Data Protection Regulation (GDPR) program in Europe. This privacy policy discloses the privacy practices for Toople, a company incorporated in England & Wales with company number 6762397 and having its registered office at PO Box 501, The Nexus Building, Broadway, Letchworth Garden City, Herts SG6 9BL, United Kingdom ("we", "us", "our"). Our website is [http://www.tooplerewards.com] (the "Website") and all associated sub-domains is committed to your privacy. This privacy policy ("Privacy Policy") is meant to help you understand what data we collect, how we use that data and the choices we offer you, including how to access and update your information.
We provide you with a program that aggregates the purchasing power of millions of individuals in order to create special pricing on a wide range of goods and services ("Program"). As a registered user of the Program, you will have access to the following features:
Online Rewards:
Discounts negotiated with companies for you to make purchases on online stores Instore Rewards: Discounts negotiated with companies for you to make purchases in stores.
Shopping Cards: Ability to purchase pre-paid shopping cards, to use instore and online
E-codes: Discount codes sent directly to you by email or text to use online or instore
By submitting personal data manually or in electronic form to us in connection with the Website you give your consent that all personal data that you submit will be processed by us in the manner and for the purposes described below. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We ensure that your personal data is processed in accordance with relevant laws and industry recognized data protection standards. At no time will we trade, sell, or distribute your personal information to any individual, company, vendor organization, in ways other than disclosed in this Privacy Policy.
If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not hesitate to contact us by e-mail at ......... or, alternatively, in writing to PO Box 501, The Nexus Building, Broadway, Letchworth Garden City, Herts SG6 9BL ("we", "us", "our"). Our website is [http://www.tooplerewards.com]
Information Collection and Use
We are committed to protecting the privacy of the users of our Website. We are the sole owner of the information collected on the Website. We will not sell, share, or rent this information to others in ways different from those disclosed in this statement. We collect information from you at several different points on the Website. By submitting your information you consent to the use of that information as set out in this policy. If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the Website will constitute your agreement to any such changes. When you submit personal information in connection with using the Website, such personal information is encrypted and protected with encryption software that lets your browser automatically encrypt data before you send it to us. While on a secure page the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just ‘surfing’.
Information We Collect
The data we collect from you may be transferred to and stored at, a destination located outside of the European Economic Area ("EEA"). By providing information to this Website you expressly consent to such information being transferred or stored outside of the EEA. We collect information for the purposes of authenticating your right to use the Program, optimizing your experience, conducting financial transactions, tracking your transaction activity at retailers in order to provide a statement of your savings, and providing you with customer service. We do not collect information that is irrelevant to the purpose of providing you with access to or use of the Program. We collect the following information: The required information is your first name, last name, email address, which are the only data that you must provide to use the Program ("Required Information"). As an eligible member of the Program, some or all of the Required Information may be provided to us by your organization or employee. By registering for the Program, you are directly providing us with the Required Information and giving us your consent to use it as set out in this Privacy Policy. The additional
personal information is the information that you may decide to voluntarily provide Us in order for Us to allow you to use additional functionality in the Program ("Additional Information").
Additional information includes
Preferences and reminders
Friends and family contact information
Address
Date of Birth
Payment and bank account information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; 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.
How We Use the Information
We use the information We collect for the following purposes:
The Required Information is used to (i) verify your affiliation with your organization, (ii) authenticate you to a unique account, (iii) communicate with you, and (iv) enable you to access the benefits and services of the Program.
The Additional Information is used to (i) facilitate additional functionality, (ii) fulfil transactions.
The Automatically Generated Information is used by Us to (i) provide you with customer service, (ii) operate your organization or employer's Rewards and Recognition Program, (iii) affect session management, and (iv)
respond to your requests All Information collected is also used to (i) protect you, (ii) prevent fraud, (iii) provide relevant offers, and (iv) optimise your experience.
Information We Share
Information about you is an important part of our business. We do not sell your information to any third parties. All information disclosing is based on the principle of sharing only the information necessary to fulfil the legitimate business purpose. When shared, data may be transferred and hosted outside the country of origin. Aggregated information showing the general use of the Program without any personally identifying information is shared with your organization to evaluate the effectiveness and value of the Program; Information on whether and when you have registered and used the Program may be provided to your organization to minimize redundant or irrelevant communications; Information on spending and savings on the Program may be provided to your organization to be included in total reward statements with other benefits you receive from your organization; RSVPs for private, in-store events may be provided to participating vendors for admittance to the event; Bank account information may be shared with our bank to facilitate payment into your account; Information may be shared with participating merchants in order to fulfil your purchase transaction, including payment information, shipping address and other personal information that may be required to complete such transaction; If your organisation has contracted a third party to run the Programme (such as a flexible benefits provider), any of the above information We share with your organisation may also be shared with the third party;
All of the information we collect, as described above, may be shared with the companies that perform the IT services on Our behalf such as credit card processors, data management firms, data analytics firms, fraud
prevention services and call center providers for the purposes of providing you with the Program and developing and maintaining it.
Disclosures of your Information
We may disclose your information to third parties in the following circumstances, where:-
(i) You consent to such disclosure; (ii) We are legally required to do so by regulatory or law enforcement authorities; (iii) We, in good faith, believe it necessary to protect the personal safety of users or the public; (iv) We (in whole or in part) merge with, or are acquired by, another business. If this happens, we may share any information or data that relates to you with any party who acquires all or part of the business; and/or (v) We are the subject of insolvency proceedings, whereby information may be disposed of in such a way as required by the courts.
Sharing
We may share aggregated demographic information with our partners, clients and advertisers. This is not linked to any personal information that can identify any individual person. We may partner with another party to provide specific services. When you sign up for these services, we will share names or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services. We may also use such aggregated information and statistics for monitoring the Website usage in order to help us develop the Website and our services and may provide such aggregate information to third
parties.
How We Protect the Information
We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, including industry-standard administrative, physical and technical controls. These controls include encryption, third-party audits, access controls and security testing.
Cookies
We use cookies to provide you with the best experience while using the Program, to manage your browser sessions and to power the Program's functionality. Cookies allow you to use all of the Program's functions as
designed. Disabling cookies will limit the functionality of the Program and significantly degrade the user experience. Some third parties (e.g., advertisers, tracking utilities) use cookies and Web beacons on their site(s). We do not have access or control over these tracking technologies. We do not share your personally identifiable data with these advertisers. This Privacy Policy covers Our use of cookies on the Program and the private label subdomains delivered by Us, only. This Privacy Policy notice does not cover the use of cookies by any third parties.
Log Files
We use IP addresses to analyse trends, administer the Website and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Data Transfers:
Because We provide the Program worldwide, this may involve Us transferring your information to countries whose data protection laws differ from the laws of the originating country.
Links
The Website contains links to other Websites. Please be aware that we are not responsible for the privacy practices of other Websites. We encourage you to be aware when you leave the Website and to read the privacy
policies of each and every website that collects personally identifiable information. This privacy policy applies solely to information collected by us on the Website.
Direct Mailings
With the exception of pre-registration emails, We do not send you unsolicited emails without your consent. We send pre-registration emails at the request of your organization. You may choose to receive correspondence, including email reminders, newsletters and Program updates. We may occasionally send out newsletters, offers or alerts to our members. We may also wish to provide you with information about special features of our Website or any other service or products we think may be of interest to you. This is an opt-in email option selected when you register to the Website. At any time you can alter your personal profile on the Website to disable any further emails. From time to time the Website may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary and you, therefore, have a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as postcode or age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use of and
satisfaction with this Website.
Opting Out
All emails sent by Us relating to the Programme contain instructions on how to unsubscribe from future correspondence. You may opt out of correspondence relating to the Programme by visiting the Contact Us page. Users may also access and edit their personal information in the "My Account" section of the website. If you would like your personal information, including email address, to be completely removed from Our database, you should use the Contact Us page. We will respond to your request within thirty (30) business days. Completely removing your personal information from the database will negate your ability to log in and use to the Program.
Subject Access Requests
You are entitled to request a copy of your personal information held by Us, as well as a description of how the information is used. A Subject Access Request should be made using the Contact Us page. To comply with the Standard Contractual Clauses (model contracts issued by the EU Commission for data transfers outside of the European Economic Area), We may need to notify and obtain authorization from your organization prior to responding to any data subject access request.
Notification of Changes to the Privacy Policy
This Privacy Policy may be reviewed and amended from time to time. You will be notified of changes to this Privacy Policy by a notice posted on the Program login page. The notice will contain a link, whereby the amended privacy policy can be examined in full. In this way, you will be made aware of policy changes prior to browsing or shopping on the Program. We may e-email periodic reminders of our notices and conditions, but you should check Our website frequently to see recent changes. As always, if you are not amenable to the conditions of a revised privacy policy you may opt out of the Program by the means outlined earlier in the 'Opting Out' section above.
Tell-A-Friend
If you elect to use our referral service for informing a friend about the Website, we will ask you for your friend’s name and email address. We will automatically send the friend a one-time email inviting them to visit the Website. We store this information for the sole purpose of sending this one-time email. This information is then discarded after the email is sent.
Merchant's Privacy Policies
Many offers on the Programme will redirect you to a participating retailer's website. An interstitial page will be displayed that will inform you that you are being redirected. At this point, you will be on the merchant website and the merchant's privacy policy will now apply to any information you provide. It is important to read and familiarise yourself with the merchant's privacy policy
Data Protection Act 1998 (the “Act”)
For the purpose of the Data Protection Act 1998 (the Act), the data controller is World Privilege Plus. We make every effort to ensure that our practices, procedures and systems comply with the relevant data protection legislation and we are registered as a data controller for the purposes of the Act. We shall only use your personal data in accordance with the legal requirements, principles and best practice recommendations of the Act, which grants you various rights in respect of the processing of your personal data.
In Summary:
World Privilege Plus is committed to protecting your privacy. We do not sell, trade, give away, or rent personal information to any third parties in ways other than disclosed in this privacy statement. We use the information collected while you are using the Program in order to make shopping and promotional activities possible and enhance your overall experience of the Program. For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit www.dataprotection.gov.uk.
Contact
If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not
hesitate to contact us by e-mail at Contact Us page or, alternatively, in writing to
Toople
Grenville Court,
Britwell Road,
Burnham,
Buckinghamshire,
SL1 8DF
United Kingdom