Introduction
Welcome to Little Wish List's - Privacy Policy.
Little Wish List Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you how we collect and handle your personal data when you visit our website (regardless of where you visit it from) or provide us with your personal details, and tell you about your privacy rights and how the law protects you. Please use the Glossary below to understand the meaning of some of the terms used.
1. Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Little Wish List Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account with us, sign up to our newsletter, purchase a product or service, take part in a competition or interact in any way with this website.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Controller
Little Wish List Limited is the controller and responsible for your personal data (collectively referred to as "Little Wish List", "we", "us" or "our" in this Privacy Policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Little Wish List Limited
Email address: hello@littlewishlist.com
Postal address: 3rd Floor, 86-90 Paul Street, London, EC2A 4NE
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance using the details above.
Changes to the Privacy Policy and your duty to inform us of changes to your Personal Data
We keep our Privacy Policy under regular review. This is the first version, uploaded on 3rd September 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links, apps and social plugins
This website may include links to third-party websites, plug-ins and applications. Clicking on those links, adding links of your own to third party websites 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. Whenever you add a link to a third party website to your list or whenever you leave our website, we encourage you to read the Privacy Policy of every website you visit.
We may share your personal data with third party app or social media providers, if you have linked your account to their app or service and, by linking your account in such manner, you hereby consent to the sharing of personal data. We recommend that you read any terms and conditions and privacy policy for any third party app provider to which your account is linked for further information as to how your personal data will be stored and processed by them. We do not accept any liability for the use of personal information by such providers.
2. The data we collect about you
"Personal data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
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.
If you fail to provide personal data
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please see the "Lawful Basis" and "Glossary" sections below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so:
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a new user of our services | (a) Identity (b) Contact | Performance of a contract with you |
| To manage our relationship with you | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests |
| To administer and protect our business and this website | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | Necessary for our legitimate interests |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, used our service or purchased goods through us and you have not opted out of receiving that marketing.
Third-party marketing
We will always obtain your express consent before we share your personal data with any third party for marketing purposes. Provided you have given your consent, we may from time to time send out emails on behalf of other businesses whose product and services may be of interest to you, or share your data with other carefully selected third parties.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message which we send to you or by contacting us at any time using the details provided above.
Cookies
To enhance your experience of our website, all of our web pages use "cookies." Cookies are text files we place in your computer's browser to store your preferences. We use cookies to understand site usage and to improve the content and offerings on our sites.
We use the following cookies:
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. International transfers
We need to share your personal data with third party suppliers of goods and services which you may purchase through us. This may involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We use the latest security technology to protect your personal information.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and regulatory purposes.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of these legal rights, please contact us using the details set out above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
10. Glossary
LAWFUL BASIS
Legitimate Interest - the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
Performance of Contract - means processing your data where it is necessary for the performance of a contract to which you are a party.
Comply with a legal obligation - means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES