Privacy Policy

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:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of donations made towards gift lists and products which you have purchased from or through us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • add an item to a list or make a payment towards a list;
  • sign up to use our services;
  • create an account on our website;
  • subscribe to our services or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers, advertising networks, and search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

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:

• Where we need to perform the contract we are about to enter into or have entered into with you, under whose terms we provide our services.
• 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.

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:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website.
• Functionality cookies. These are used to recognise you when you return to our website.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed.

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:

• Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

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:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to the processing of your personal data.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

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

• Service providers acting as processors based inside and outside the EEA who provide IT and system administration services.
• Third party retailers supplying products within the content of any list created by our users.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.