1.1 We are WEAREKOOKI LIMITED (referred to as we, "us" and "Kooki") and we are committed to protecting and respecting your privacy when you are
(a) visiting any website maintained by us including without limitation the website at www.getkooki.com and our Facebook and Twitter pages (together the "Website");
(b) using any application maintained by us including without limitation any application provided for the iphone and android platforms (together the "Application"); or
(c) or communicating electronically with us.
1.2 This policy, together with the Terms of Service (which can be found at the bottom of the Website), explains what types of personal and non-personal information we collect when you use the Website and 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. If you do not agree with this policy, you must cease use of the Website and the Application immediately.
1.3 Kooki uses the personal information we collect from you to provide our service to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.
1.4 For the purpose of the Data Protection Act 1998 (the Act), the data controller is WEAREKOOKI LIMITED of 23 William Road, London NW1 3EU which is registered with the ICO with registered number [...].
1.5 As set out in paragraph 6 below, we will from time to time disclose your personal information to our Merchants (as defined below). In these circumstances, the relevant Merchant will be the data processor for the purpose of the Act.
2. INFORMATION WE MAY COLLECT FROM YOU
In order to provide you with the best possible service, we may collect and process the following data about you:
Information you provide us
2.1 When you download the Application, we ask you to register and provide us with personal information as follows: Your name, email address and password.
2.2 There are also opportunities within the Website and Application to provide the email addresses or contact details of your friends or family members and your social networking site login details to allow you to tell people about Kooki. We may use the information you provide us along with your browsing details, to provide you with a better experience when using the Application or Website. We will always provide you with the opportunity to opt out of receiving any communication via email.
2.3 We may also ask you for information from time to time including when you report a problem with our Website or Application.
2.4 If you contact us, we may keep a record of that correspondence.
2.5 We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
Usage and browsing information
2.6 As part of the standard operation of the Application, we may collect certain non-personal information from you. For example, when you upload, view, or register a stamp or create a loyalty card with one of our retail partners (each a "Merchant"), the Application may send to us basic information about your browsing and the activities that you have performed. This may include dates and times and information relating to the stamp or loyalty card. We may combine this non-personal information with your personal information.
2.7 We may also record details of your visits to and use of the Website and Application including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
2.8 We may collect information about your computer or mobile advice, including where available your IP address, operating system and browser type, for system administration. To the extent required we may provide this information to third parties. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
2.9 If you access the Website through a mobile telephone, we may receive a unique identifier for your phone if your handset manufacturer or network provide it. We may use your unique mobile device identification information to offer you extended functionality. We may associate that information to the mobile device identification information and to other information we have collected from and about you; however we will not use that number to telemarket to you.
Information you provide on third party websites
2.10 You might find links to third party websites on the Website or Application. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
3.1 We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve the Website and Application and to deliver a better and more personalised service. Some of the cookies we use are essential for the Website and Application to operate.
4. WHERE WE STORE YOUR PERSONAL DATA
4.2 All information you provide to us is stored on our secure servers.
4.3 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 through our Website; 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.
5. USES MADE OF THE INFORMATION
5.1 We use information held about you in the following ways:
(a) to ensure that content from the Website is presented in the most effective manner for you and for your computer or telephone;
(b) to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
(c) to carry out our obligations arising from any contracts entered into between you and us;
(d) to allow you to participate in interactive features of our service, when you choose to do so; and
(e) to notify you about changes to our service.
6. DISCLOSURE OF YOUR INFORMATION
6.1 We will disclose personal information about you to our Merchants in the following circumstances:
(a) when you redeem a voucher (having collected the requisite number of stamps) we will confirm to the Merchant that you have collected the relevant stamps, your name and email address.
(b) we will disclose to our Merchants the names of their top customers in each period; and
(c) we will disclose to our Merchants aggregated information about the number of visits to their store and the average frequency of their visits.
6.2 We may also disclose your personal information to third parties:
(a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(b) if Wearekooki Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
(c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of Wearekooki Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. OWNERSHIP OF INFORAMTION
7.1 Information relating to your use of any loyalty scheme, the number of stamps registered by you in respect of any loyalty scheme and record of redeeming vouchers derived from any loyalty scheme (as well as any aggregated data created by us and including the above information) shall be owned by Kooki.
7.2 Kooki grant you a licence to use, view and download such information for personal non-commercial purposes during such time or you use the application and the Terms of Service remain in full force and effect.
8. YOUR RIGHTS
8.1 The Act gives you the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
8.2 The Website and/or Application may, from time to time, contain links to and from the websites of third parties. 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.
9. ACCESS FOR INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.