Privacy Policy

Privacy and Cookies Policy

At I Choose Local Limited we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).  We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

  

We, us, our

I Choose Local Limited a company registered in England and Wales under company number: 11199453

   [Our data protection officer]

Gary Hudson

Personal data

Any information relating to an identified or identifiable individual

Special category personal data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data (when processed to uniquely identify an individual)

Data concerning health, sex life or sexual orientation

Data subject

The individual who the personal data relates to

Personal data we collect about you

As a result of your use of the I Choose Local Limited platforms and app as a subscriber or user we may collect and use the following personal data about you:

  • your name and contact information, including email address [and telephone number]
  • [information to check and verify your identity, eg your date of birth]
  • [your gender[, if you choose to give this to us]]
  • [location data[, if you choose to give this to us]]
  • [your personal[ or professional] interests]
  • [information from accounts you link to us[, eg Facebook]]
  • Information about how you use the I Choose Local Limited app and our website

We also collect and process any personal data or special category personal data that you upload into the I Choose Local Limited app and/or our website as part of your use of the I Choose Local Limited app.

We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this personal data directly from you via the I Choose Local Limited app and/or our website.  However, we may also collect information:

  • From the app store that you use to download the I Choose Local Limited app
  • from a third party with your consent, eg when another user of the I Choose Local Limited app uploads information to the I Choose Local Limited app which involves you.
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  • where you have given consent;
  • to comply with our legal and regulatory obligations;
  • for the performance of a contract with you or to take steps at your request before entering into a contract; or
  • for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

  

What we use your personal data for

Our reasons

Providing services to you

To perform our contract with you or to take steps at your request before entering into a contract

Preventing and detecting fraud against you or us

For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us

[Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by our professional regulator]

[To comply with our legal and regulatory obligations]

[Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies]

[To comply with our legal and regulatory obligations]

Ensuring business policies are adhered to, eg policies covering security and internet use

For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, eg in relation to [our financial performance, customer base, product range or other efficiency measures]

For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for you and/or us

To comply with our legal and regulatory obligations

Updating and enhancing customer records

To perform our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services [and those of selected third parties] to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, ie to promote our business to existing and former customers

[Credit reference checks via external credit reference agencies]

[For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services]

External audits and quality checks, eg for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

When you upload special category data to the I Choose Local Limited app, you consent to the processing of that special category data by us and/or our sub-processors where appropriate.

Marketing

We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts[; or]
  • updating your marketing preferences on our website

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

We may anonymise your data in order to share such data with third parties.  When we anonymise personal data this means that the data is not capable of being used to identity you and it therefore ceases to be personal data.

Who we share your personal data with

We routinely share personal data with third parties we use to help deliver our services to you, namely:

  • Digital Ocean
  • AWS
  • Banntech Limited, 217 Brook Street, Broughty Ferry, Dundee, DD5 2AG

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

  • share personal data with external auditors, eg in relation to the audit of our accounts;
  • disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
  • share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK[/EEA]. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK[ and EEA]’.

How long your personal data will be kept

We will keep your personal data while you have an account with us or we are providing services to you. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.

When it is no longer necessary to keep your personal data, we will delete or anonymise it.

Transferring your personal data out of the UK[ and EEA]

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK[/EEA], eg:

  • with your and our service providers located outside the UK[/EEA];
  • if you are based outside the UK[/EEA];
  • if you are in a family group on the I Choose Local Limited app with individuals who are outside of the UK/EEA;
  • [where there is a European and/or international dimension to the services we are providing to you.]

We will only allow access to your data by an individual outside of the UK/EEA where they are a subscriber or user of the I Choose Local Limited app and you are in a family group with that individual.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK[/EEA] where:

  • the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
  • a specific exception applies under data protection law

These are explained below.

Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

  • all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
  • Gibraltar; and
  • Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:

  • you have explicitly consented to the proposed transfer after having been informed of the possible risks;
  • the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
  • the transfer is necessary for a contract in your interests, between us and another person; or
  • the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Further information

If you would like further information about data transferred outside the UK[/EEA], please contact [us OR our Data Protection Officer] (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

  

Access

The right to be provided with a copy of your personal data

Rectification

The right to require us to correct any mistakes in your personal data

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object

The right to object:

—at any time to your personal data being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

  • email, call or write to us—see below: ‘How to contact us’; and
  • provide enough information to identify yourself and any additional identity information we may reasonably request from you;
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Cookies

Our cookie policy only relates to your use of our website.

Our 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.

What is a Cookie?

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website.

We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested

You can withdraw any consent to the use of cookies or manage any other cookie preferences by editing your cookie acceptance settings

Our use of cookies

The table below provides more information about the cookies we use and why:

The cookies we use

Name

Purpose

Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie

[Describe the type of cookie, including its owner eg ‘Universal Analytics (Google)’]

[Insert cookie name(s) eg _ga, _gali, _gat, _gid]

[Insert a general description, eg: This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.]

This cookie collects [information in an anonymous form including: [insert] OR personal information including: [insert].]

[Insert details of how long the cookie will remain—see drafting notes for alternative text.]

Read [insert link to third party guidance on how the third party (eg Google or Youtube) uses the cookies and the data generated by them where relevant].

[Insert, eg [Yes, essential (we will therefore not request your consent before placing this cookie) OR No, will therefore request your consent before placing this cookie]]

[Insert details of other cookies]

[Insert details of other cookies]

[Insert details of other cookies]

[Insert details of other cookies]

Third party access to the cookies

[Insert details of any third party access to the cookies and the names of the relevant third parties or confirm there is no such third party access as appropriate. Eg ‘The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party.’]

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

You can manage your cookie settings by following your browser’s instructions. Here are some links that might be of assistance:

 

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

How to complain

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on [20/08/2021 and last updated on [21/08/2021]

We may change this privacy notice from time to time—when we do we will inform you via [insert mechanism for informing the data subject of changes to the notice, eg our website or other means of contact such as email].

How to contact us

Individuals in the UK

You can contact us[ and/or our Data Protection Officer] by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

[Our Data Protection Officer's contact details]

I Choose Local Limited

Summit House, 33 Hanworth Road

Sunbury Upon Thames, TW16 5DA

data@ichooselocal.co.uk

Summit House, 33 Hanworth Road

Sunbury Upon Thames, TW16 5DA

Individuals in the EEA

We have appointed [insert full legal name] to be our data protection representative within the EEA. Their contact details are [insert full contact details].

Individuals within the EEA can contact us direct (see above) or contact our European representative.

[Do you need extra help?]

[If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).]