1. SOURCES OF PERSONAL DATA
This Policy applies to Personal Data that Podback Limited ( “we”, “us”, “our”) collect from or about you. If you use our website or deal with us, not only may you submit personal data or information but, through the methods described below (see Section 2), we will collect data from you through the following sources.
By using the website, or passing personal data to us in the matter, this is taken as your personal positive consent for us to use that data as described below.
The Podback Website: The website operated by or for us, including websites that we operate under our own domains/URLs (“Website”);
Email, text and other electronic measures: Electronic communications between you and Us;
Data from other sources: Third-party social networks (e.g.. such as Facebook, Google) or market researches (if feedback is not provided on an anonymous basis).
2. PERSONAL DATA THAT WE COLLECT ABOUT YOU, AND HOW WE COLLECT IT
Depending on how you interact with us (online, offline, over the phone etc.), we collect various types of information from you, as described below:
Personal contact information: This includes any information you provide to us that would allow us to contact you; such as your name, postal address, email address, social network details or phone number.
Demographic information and interests: Any information that describes your demographic or behavioural characteristics. Examples include your date of birth, age or age range, gender, geographic location (e.g. postcode), favourite products, hobbies and interests, and household or lifestyle information.
Technical information about computer/mobile device: Any information about the computer system or other technological device that you use to access our website, such as the Internet Protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access the website via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location and other similar mobile device data.
Websites/communication usage information: As you navigate through and interact with our website or other information we send or publish, we may use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies (browser cookies, flash cookies,) and web beacons, and is also collected through the use of third-party tracking. You have the right to object to the use of such technologies, for further details please see Section 3 and our Cookies Policy.
Market research and consumer feedback: This includes information that you voluntarily share with us about your experience of using our products and services.
Consumer-generated content: This refers to any content that you create and then share with us on third-party social networks or by uploading it to our website or apps, including the use of third-party social network apps such as Facebook. Examples include photos, videos, personal stories or other similar media or content and posts. Where permitted, we collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement and third-party social networking.
Third-party social network information: This refers to any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Facebook) and that you allow the third-party social network to share with us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share. We may receive your third-party social network profile information (or parts of it) every time you download or interact with a Podback web application on a third-party social network such as Facebook every time you use a social networking feature that is integrated within the website (such as Facebook Connect) or every time you interact with us through a third-party social network.
Email: We analyse your interactions through our content (e.g. click through, the opening of email) to provide you with personalised information based on your interests and preferences.
3. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS
Log files: We collect information in the form of log files that record website activity and gather statistics about your browsing habits. These entries are generated automatically, and help us to troubleshoot errors, improve performance and maintain the security of our website.
Web beacons: Web beacons (also known as ‘web bugs’) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to us. The information collected via web beacons will include information such as IP Address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We will use web beacons on our website or include them in emails that we send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalisation.
4. USES MADE OF YOUR PERSONAL DATA
The following paragraphs describe the various purposes for which we collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
|What We use your Personal Data for||Our reasons||Our legitimate interests|
|Customer service: Including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your enquiry (e.g. order status, technical issue, product question/complaint, general question) relayed via our communication channels and/or social media channels.|
|Contests, marketing and other promotions: With your consent (where required), we use your Personal Data to provide you with information about goods or services. This can be done via means such as email, ads, SMS, phone calls and postal mailings to the extent permitted by applicable law. This use of your Personal Data is voluntary, which means that you can oppose the processing of your Personal Data for these purposes. For detailed information on how to modify your communication preferences please see Sections 8 and 9 of this Policy.|
|Third party social networks: We use your Personal Data when you interact with third-party social networking features, such as ‘Like’ functions, to serve you with advertisements and engage with you on third-party social networks.|
ou can learn more about how these features work, the profile data that we obtain about you, and find out how to opt-out by reviewing the privacy notices of the relevant social networks.
|Personalisation (offline and online): With your consent (where required) we use your Personal Data (i) to analyse your preferences and habits; (ii) to anticipate your needs based on our analysis of your profile; (iii) to improve and personalise your experience on our Website and apps; (iv) to ensure that content from our Website/apps is optimised for you and for your computer and device; (v) to provide you with targeted advertising and content. The use of your Personal Data is voluntary, which means that you can oppose the processing of your Personal Data for this purpose. For detailed information on how to opt-out please refer to Section 8 below.|
|Order fulfilment: We use your Personal Data to process and ship your orders, inform you about the status of your orders, correct addresses and conduct identity verification and other fraud detection activities. This involves the use of certain Personal Data.|
|Other general purposes (e.g. internal or market research, analytic security): In accordance with applicable laws. We use your Personal Data for other general business purposes, such as conducting internal or market research and measuring the effectiveness of advertising campaigns. We also use your Personal Data to ensure our security.|
|Legal reasons: We will share your Personal Data with any of our legal successors and Company Members (Podback is an English company limited by guarantee under English law and its membership is drawn from the coffee industry and associated sectors). We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of our Website.|
5. DISCLOSURE OF YOUR PERSONAL DATA
In addition to the Podback corporate membership and as mentioned in the data controllers and contact section (see Section 11), we share your Personal Data with the following types of third-party organisations:
Service providers: These are external companies that we use to help us run the Podback business activities (e.g. the logistics of various used beverage pod collections, collection bags, pod reprocessing, recycling and valorisation, fraud detection and identity verification, Website operation etc). Service providers and their selected staff are only allowed to access and use your Personal Data on our behalf for the specific tasks that they’ve been contracted to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. Where required by applicable law, you can obtain a list of the providers processing your Personal Data (see Section 11 to contact us). These service providers are Processors of your Data (and may, where allowed, use Sub-Processors) and in some circumstances may be Controllers of your Personal Data).
Third-party companies using Personal Data for their own marketing purposes: Except in situations where you have given your consent, we do not license or sell your Personal Data to third-party companies for their own marketing purposes. Their identity will be disclosed at the time your consent is sought.
6. RETENTION OF YOUR PERSONAL DATA
Retention of your Personal Data: In accordance with applicable laws, we will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected (as described in Section 4 above) or to comply with applicable legal requirements.
Personal Data used to provide you with a personalised experience (see Section 4 above for details) will normally be kept for two years, or some other duration permitted by applicable laws.
Nothing in this Policy overrides Data Protection Law in the United Kingdom, and accordingly you have a general right to have your Personal Data removed. To effect this, please contact us at: firstname.lastname@example.org
7. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We use a variety of reasonable measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.
People who can access your Personal Data: Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data has been collected.
Measures taken in operating environments: We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although we will do our best to protect your Personal Data we cannot guarantee the security of the data during transmission through our Website/apps.
Transfer of your Personal Data: The storage as well as the processing of your Personal Data as described above require that your Personal Data is ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence; notably Ireland and Germany. We will not transfer your Personal Data to countries outside the European Economic Area (“EEA). If we ever do have to do that, these Terms shall be updated and we will first put in place suitable UK and European Commission-approved standard contractual clauses to protect your Personal Data (and you have a right to ask us for a copy of these clauses by contacting us as set out below).
8. ACCESS TO YOUR PERSONAL DATA
Access to Personal Data: Where provided by law, you, your successors, representatives and/or proxies have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data.
These rights can be exercised by writing to us at email@example.com with a copy of your ID or equivalent details (where requested by us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
Please note that any identification information provided to us will only be processed in accordance with, and to the extent permitted by applicable laws.
Additional rights (e.g. modification, deletion of Personal Data): Where provided by law, you, your successors, representatives and/or proxies can (i) request deletion, the portability, correction or revision of your Personal Data; (i) oppose the data processing; (iii) limit the use and disclosure of your Personal Data; and (iv) revoke consent to any of our data processing activities.
Please note that, in certain circumstances, we will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.
We hope that we can satisfy queries you may have about the way we process your Personal Data. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities (in the United Kingdom this is the Information Commissioner’s Office at www.ico.org.uk).
9. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We strive to provide you with a choice regarding the Personal Data that you provide to us. The following mechanisms give you the following control over your Personal Data:
Cookies/Similar Technologies: You manage your consent via (i) Our consent management solution, or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 3 above.
Advertising, marketing and promotions: If you wish to have your Personal Data used by us to promote our products or services, you can indicate so through the relevant tickbox(es) located on the registration form. If you decide that you no longer wish to receive such communications, you can subsequently unsubscribe from receiving marketing-related communications at any time, by following the instructions provided in each such communication.
To opt-out of marketing communications sent by any medium, including third-party social networks, you can opt-out at any time by logging into the Website/apps or third-party social networks and adjusting your user preferences in your account profile by unchecking the relevant boxes.
10. CHANGES TO OUR POLICY
If we change the way we handle your Personal Data we will update this Policy. We reserve the right to make changes to our practices and this Policy at any time. Please check back frequently to see any updates or changes to our Policy.
11. DATA CONTROLLERS AND CONTACT
To ask questions or make comments on this Policy and our privacy practices, or to make a complaint about our compliance with applicable Privacy laws, please make contact by writing to us at firstname.lastname@example.org or by post to Podback Limited, c/o Cumberland House, 15-17 Cumberland Street, Southampton SO15 2BG.
We will acknowledge and investigate any complaint about the way we manage Personal Data (including a complaint that we have breached your rights under applicable privacy laws).
Cumberland House, 15-17 Cumberland Street, Southampton SO15 2BG