Useyourlocal Limited, (“we”, “our”, “Useyourlocal”) are committed to protecting and respecting the privacy of all of our visitors and users. Please read the following carefully to understand our views and practices regarding your data and how we will treat it.
If you have any questions, comments or requests on this policy or how we use your data, please contact us at firstname.lastname@example.org. We are a company registered under the laws of Scotland with registration number SC349564. Our ICO registration number is Z1666338. You have the right to make a complaint at any time to the Information Commissioner’s Office (the UK’s supervisory authority for data protection issues). However, we appreciate the opportunity to deal with your concerns before you approach the ICO, so would be grateful if you contacted us initially if you have any complaints or concerns. The Information Commissioner’s Office can be contacted on 0303 123 1113 or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
This policy applies when you visit our website at www.useyourlocal.com and any related websites and mobile applications, and including any pub or bar websites that are “powered by” useyourlocal.com (these sites are referred to as “Websites” below), including where you register for an account with us, and applies to any data we collect from you, or that you provide to us.
By visiting our Websites and/or when registering for an account with us, you will be accepting and consenting to the collection, use and transfer of your information as set out in this policy.
Where used in this policy, the term “participating outlet” means any pub or bar that has a profile page on the Website.
This website is not intended for children and we do not knowingly collect data relating to children.
1. What information do we collect from you?
We will collect and process the following data about you:
- information that you give us by filling in forms on our Websites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Websites, subscribe to our services, search for bars, pubs and restaurants, post content, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, date of birth, address, e-mail address, phone number, financial and credit card information, personal description and photograph.
- technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, this may also include technical information through your use of mobile devices such as location data, characteristics of your device, operating systems, mobile payment methods, interaction with other retail technology such as QR codes, pixel tags, web beacons, NFC tags or mobile vouchers. Unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you use the websites or our services through your mobile device(s), through your mobile’s browser or otherwise.
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products and participating outlets that you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- information we receive about you if you use any of the other websites we operate or the other services we provide, or if you visit and use any of the Websites “powered by” us (for example this includes websites of pubs and participating outlets that are registered to use our service – although they will have their own privacy terms on their website and we encourage you to read the privacy policies on those websites). We may share your data internally and combine it with data collected on this site and combine this for our own internal business purposes. 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).
- Information we receive about you through your login to our Website via social media, for example through Facebook, Instagram and Twitter. This will include your user name, profile details (including profile picture), and details of your interactions with other users of our Website.
- We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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, to provide you with certain services). In this case, we may have to cancel the services you are due to receive from us but we will notify you at the relevant time if this is the case.
2. How do we use and share your information?
When you register to use the Website, your notifications will default to “on”. You can change your preferences for the way we contact you from time to time in the “preferences” section of the Website.
We will only use your personal data when the law permits us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into (or have entered into) with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you would like more details about the specific legal ground we are relying on to process your personal data, please contact us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like us to explain how processing for another reason is compatible with the original purpose, please contact us.
We will not disclose your personal data to any third parties unless we have your consent or where we are entitled to do so by law. Where we do disclose your personal data to a third party, we will have regard to the data protection principles. If we use any third parties to process any personal data on our behalf, we do not allow those third parties to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
If your personal data is provided to any third parties, you are entitled to request details of the recipients of your personal data or the categories of recipients of your personal data.
We will use the information that we collect from you for the following purposes:
- to provide you with the information, products and services that you request from us, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. Our legal basis for processing your personal data in this way is performance of a contract with you / necessary for our legitimate interests;
- where you have “followed” a pub, bar or outlet on our Website, to allow that outlet to directly communicate with you via email via the Website, including to allow that outlet to provide you with details of offers and promotions available to you;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- where you register to use the Website, your details will appear on the “people” page of useyourlocal.com. This will allow outlets and other users to see your profile page and all activity published by you through the Website, including but not limited to your name, profile photo and the pubs and bars that you “follow”, and lists of pubs created by you;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to directly contact you with messages from us and our selected third parties, including marketing and advertising businesses, affiliates and associates with information about goods or services that may interest you. Contact may be by, SMS and email, or via the Website and through smart technology (for example beacons). For example, we might allow a drinks brand to contact users in Birmingham with details of a promotion being run by them. This message would be sent by us on their behalf. If you change your mind, and do not want us to use your data in this way, please contact us on the details set out above, or change the preferences on your online account with us);
- to ensure that content from our site is presented in the most effective manner for you.
- If our business enters into a partnership with another business, or we purchase another business or we are sold or merged to another business, your information may be disclosed or transferred to these new business partners and their owners and advisors.
- To share information with our business partners (for example our participating outlets and retailers/brands, analytics and search engine providers, and advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to these third parties, but we will provide them with aggregate information about our users (for example, if a drinks brand runs a promotion through our service, we may inform them and other third parties and participating outlets that 500 men aged under 30 have clicked on their advertisement, and/or that 200 of these men redeemed a voucher for that promotion on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, in the example given above we might tell these third parties that of the 200 men who redeemed the voucher, the participating outlets in which the voucher was redeemed, and other characteristics of the individuals (for example 25% of them lived in the postcode NE1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
- Please note that by submitting reviews regarding the website, service and/or participating outlets, you consent to us using such reviews on our website, partner websites, and with all other third parties (such as brand owners, marketers and advertisers) and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you reside (and any other information that you may from time to time consent to us disclosing).
3. Only processing the personal data that we need to
Your personal data will only be processed to the extent that it is necessary for the specific purposes we tell you about.
4. Where we store your personal data
We will not transfer your personal data outside the European Economic Area (“EEA”) unless such transfer is compliant with the GDPR. This means that we cannot transfer any of your personal data outside the EEA unless:
- The EU Commission has decided that another country or international organisation ensures an adequate level of protection for your personal data; or
- The transfer of your personal data is subject to appropriate safeguards, which may include:
- Binding corporate rules; or
- Standard data protection clauses adopted by the EU Commission; or
- One of the derogations in the GDPR applies (including if you explicitly consent to the proposed transfer).
- The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. As our business grows it may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
5. Your rights
You have the right to:
- Request access to any personal data we hold about you.
- Have any inaccurate personal data which we hold about you rectified.
- Have incomplete personal data completed.
- Have personal data erased, in certain circumstances.
- Have the processing of your personal data restricted, in certain circumstances.
- In certain circumstances, be provided with the personal data that you have supplied to us, in a portable format that can be transmitted to another data controller without hindrance.
- Object to certain types of processing, including automated processing (which includes profiling) and processing for direct-marketing purposes.
- In certain circumstances, the right not to be subject to a decision that is based solely on automated processing which produces a legal effect or which has a similar significant effect for you.
You have the right to object, at any time:
- to the processing of your personal data which:
- is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
- which is necessary for the purposes of the legitimate interests pursued by us or a third party, including profiling.
If you object to the processing (as set out above), we must no longer process that personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims.
If you wish to exercise any of the rights set out above, you must make the request in writing to email@example.com. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may choose not to comply with your request in these circumstances.
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 your personal data is not disclosed to any person who has no right to receive it. We may also ask you for further information in relation to your request to speed up our response.
If you provided your consent to any of the processing of your personal data, you have the right to withdraw your consent to that processing at any time, where relevant. Please contact firstname.lastname@example.org if you wish to do so.
We seek to respond to all legitimate requests within one month. From time to time, it may take us longer than a month if your request is particularly complex or you have made a number of requests. If this is the case, we will notify you and keep you updated.
- It is important that the personal data we hold about you is accurate and up-to-date. If any of your personal data changes during your relationship with us, please let us know as soon as possible. You can update this on your online account at www.useyourlocal.com. We will take every reasonable step to erase or rectify inaccurate data without delay. We may contact you from time to time to check your details are still up-to-date. We will also contact you if we become aware of any event which is likely to result in a change to your personal data.
- Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that 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.
6. Data retention
We keep your information only as long as we need it for the purposes for which we process it and as permitted by applicable legal requirements, such as for tax and accounting purposes, or as otherwise communicated to you. This means that personal data will be destroyed or erased from our systems when it is no longer required.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances (including if you close your account) we will anonymise your personal data (so that you cannot be directly or indirectly identified by that data) and we will retain this data for analytical, research and statistical purposes and recordkeeping integrity. In this case we may use this information indefinitely without further notice to you.
If your data has been passed to third parties, its retention by them will be subject to their own data retention policies.
7. How we keep your data secure
- We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
- We have in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We will only transfer personal data to a third party if that third party agrees to comply with those procedures and policies, or if they put in place adequate measures themselves.
- Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data.
- All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. 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, 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.