Privacy Policy

Date: 24/05/2018

Version P18.1

 

Introduction to Privacy Policy

 

The aim of Our Privacy Policy is to clearly outline to You:

 

  • what data We/Us/Our (Flubit Limited) will collect at different times when You use Our service;
  • how We may use that data;
  • how long We may store that data;
  • how You/Your (the human user of the website or service) may opt-out of Us using or storing that data;
  • and where We may send that data (outside of Flubit) for Us to operate Our service (both critical use and optional use).

 

Inside this Privacy Policy We also identify which information is optional to provide to use Our service (for example: some marketing related activities), and which information is critical (for example: data We need to fulfil an order via Our suppliers).

 

To use the Flubit service We have made it easy for You to view which information We will store, and You can change Your preferences at any time at the following link: https://flubit.com/account/mydata

 

We use industry standard efforts to safeguard the confidentiality of Your personal identifiable information, such as firewalls and Secure Socket Layers where appropriate.

 

We have separated the remainder of the Policy into the following sections:

 

  1. The data We collect for Our core (critical) service
  2. The data We share with 3rd parties
  3. How We may use Your data for marketing purposes and additional data We may request permission for
  4. Information about storing Your information
  5. Your rights over Your data
  6. Future changes to Our privacy policy

 

 

  1. The data We collect for Our core (critical) service

 

Flubit is an online shopping website that requires certain information from You in order to run its service. The following information in the table below is deemed as critical to Our business, depending on how much You interact with Us (for example: We need more information from You if You purchase from Us, compared to if You simply sign up for an account). For avoidance of doubt, this information does not include instances where Flubit may need to use Your data to comply with legal and/or regulatory purposes.

 

Information We Use

How & Why We may use the data provided

When does this become critical?

Email

Create a username and log in

To contact You if there is an issue with Your order and update You with delivery information.

Customer service may use this to verify Your identity and assist You

Fraud detection and prevention against You or Flubit Ltd

Account verification purposes

When You sign up to the service.

Your Full Name

 

Deliver Your order by sending this information to Our merchants to fulfil

Customer service may use this to verify Your identity and assist You

To contact You if there is an issue with Your order and update You with delivery information.

Fraud detection and prevention against You or Us.

When You make a purchase, We will ask for a Delivery Name and a Billing Name.

Delivery address (including postcode)

Phone number

Deliver Your order by sending this information to Our merchants/sellers to fulfil

Verify Your identity

To contact You if there is an issue with Your order or a product recall.

Contact You about Your order delivery status

Fraud detection and prevention against You or Flubit Ltd

When You make a purchase, We will need this information to deliver an item and fulfil post-order actions.

Product purchase details and history

Deliver Your order by sending this information to Our merchants to fulfil

For Our customer service team to verify Your identity and assist You with Your orders.

Train Our customer service team

For accounts and regulation reasons.   

When You make a purchase, We will need to record this data for future actions relating to customer service and accountancy.

Credit card information

 

We do not keep a record of Your credit card information, We use a secure 3rd-party service (Stripe) to process Your payment for Your order on Our service.

Your payment information is tokenised by this 3rd party service which allows Us to issue You a refund should We need to and allow You check out faster if You are logged in to flubit.

When You make an order, so we can take payment and make actions in the future (for example: refunds).

Anonymous Aggregate data

To create internal reports, test Our IT systems, research, data analysis, improving Our site, building & developing Our Website or developing new products or services.

We only use and share this information with third parties when it is anonymous i.e. without identifying information

We use anonymous aggregated data at all times on Our service.

 

  1. The data We share with 3rd parties

 

We do not sell or intend to share any of Your personal details to third parties, excluding instances and purposes listed in this section.

 

We share some data with the following third parties in order for Us to carry out business, deliver a great customer service experience to You and improve Our business. As the service evolves We may add services to this list.

 

Further information about 3rd parties that may store data about You (either anonymous or identifiable)  about You can be found in Our Cookie Policy.

 

3rd Party

URL

Why we use this service

Google Analytics

https://analytics.google.com/ 

We use Google Analytics to track anonymous data about Our website and service usage. Google collects data via a cookie on Our website.

Floodlight

https://www.doubleclickbygoogle.com/ 

 

We use this service to help track anonymous data relating to the success of Our offline media (e.g. TV).

Mindshare

www.mindshareworld.com 

 

Mindshare are a marketing agency who we work with to improve the quality of Our advertising campaigns. Mindshare track anonymised data via a cookie on Our website. 

Zendesk

www.zendesk.co.uk 

 

When You leave a customer support request on Flubit, the data provided is managed and shared with ZenDesk

Stripe

https://stripe.com/ 

 

Stripe is a payment processor who stores and manages Our online transactions. We will send them all information relating to payment and order details You provide.

Gleam

https://gleam.io/ 

We use gleam to process some competitions we run from time to time. They will collect all information You provide on a competition entry.

Instapage

www.instapage.com/‎ 

 

Sometimes we build landing pages on Instapage to help deliver messages to Our customers quicker. Sometimes we will collect information on this page, the information You provide will be shared with Instapage.

Pricespy

https://pricespy.co.uk 

Pricespy promote Our products and we help them understand which of these products have been purchased.

AWIN

www.awin.com/‎ 

AWIN and their publishers promote Our products and we help them understand which of these products have been purchased.

Pricesearcher

https://www.pricesearcher.com 

Pricesearcher promote Our products and We help them understand which of these products have been purchased.

Idealo

https://www.idealo.co.uk 

 

Idealo promote Our products and We help them understand which of these products have been purchased.

Instiller

https://instiller.co.uk/ 

Instiller acts as Our newsletter/mailing list provider. We send Instiller all the information we need to process Our email communication on Flubit.com

Facebook

Instagram

Twitter

https://facebook.com

https://instagram.com

https://twitter.com 

 

We use Our social channels to feed organic information about Flubit and also, where permission is granted (see section 3) for multiple format targeting and re-targeting campaigns. Facebook targets its own users, we also send cookie data for the remarketing and basket abandonment where permission is granted. 

Bing

Google Shopping

https://bing.com

These services promote Our products and We help them understand which of these products have been purchased.

 

 

We may provide further data to third parties not listed above, but before We do so We ensure that all data is anonymous meaning it cannot be identified as You.

 

There are three reasons where we may share Your data with 3rd parties that we have not listed here:

 

  • Professional Advisers and Investors: We may also share Your data with professional advisers such as Our lawyers and insurers to manage risks and legal claims, and/or as part of Our relationship and obligations to Our investor organisations. This is in Our legitimate interests.

 

  • Group: It is possible we could sell Our business to a third party or re-organise Our business or become insolvent. In that scenario, Our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling Our business.

 

 

  • Law Enforcement/Legal Compliance: We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement requests from within or outside Your country of residence. This may include disclosing Your personal information to government or law enforcement agencies, or private parties, when we have a good faith belief that disclosure is required by law or when we, in Our discretion, believe that disclosure is necessary to protect Our legal rights, or those of third parties and/or to comply with a judicial proceeding, court order, fraud reduction or legal process served on Us. In such cases, we may raise or waive any legal objection or right available to Us. These uses of Your data are in Our legitimate interests of protecting Our business security. We may also use Your data and share it with the recipients listed in this Privacy Policy for the purpose of complying with Our legal obligations.

 

 

 

  1. How We may use Your data for marketing purposes and additional data We may request permission for.

 

Part of the role of the Flubit team is to market Our products and services to enable more people to purchase items listed on Our website. To do so We use a number of different 3rd parties to help Us with these initiatives. Those 3rd parties are listed in Section 2, and unless stated otherwise anonymised information about Your interactions with Flubit is sent to these services. We see these anonymised transfers of data as critical to the running and future success of Our business and You cannot opt-out of them if You use Flubit.

 

In addition to the anonymised data we send to 3rd parties, We may ask permission from You to use extended data to help give You a better service. A better service may include (but is not limited to),

 

  • the ability for Us to personalise Our email communication to You based on identifiable information (e.g. name, DOB);
  • the ability for Us to place advertisements (including product listings) on 3rd party websites based on Your browsing or purchasing history with Us;
  • whilst browsing Flubit.com, having Us push relevant deals and information to You based on Your specific interactions with the website.

 

For this We will ask You to opt-in to Our marketing initiatives; You will automatically be opted-out of these services when You join Flubit. If at any stage You would like to opt in or out You can do so in Your account settings – https://flubit.com/account/privacy/ ;

 

The additional data We will request permission to use to send to 3rd parties is as follows:

 

Data provided by You

Use

Email address

To identify You on 3rd party services and internally.

Name

To improve user experience with email and advertising personalisation and re-targeting.

Date of birth

Allows Us to offer You exclusive discounts in celebration of Your birthday.

Helps Us identify product deals more relevant to You based on purchases of other people in Your age demographic.

Gender

Helps Us identify product deals more relevant to You, and improve service based on learnings of others similar to You.

 

Other data we use

Use

Purchase data

Helps Us identify product deals more relevant to You.

Email engagement data

For engagement analysis and optimisation.

 

 

 

 

  1. Information about keeping Your information

 

We keep Your information for as long as it is seen necessary to uphold Our obligations to: deliver Your order, meet government regulations (for example: relating to accountancy) improve Our service to You, prevent fraud and for law enforcement purposes.

 

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce Our terms and conditions, We may also keep hold of some of Your information as required, even after You have closed Your account, or it is no longer needed to provide the services to You.

 

To give You a better understanding, we usually keep financial records (including information about orders & transactions) for 7 years. We will keep top-level information (for example relating to the total quantity of sales transacted in a year) for as long as We as a business deem it useful.

 

  1. Your Rights over Your data

 

You have the following rights when it comes to Your personal information

 

  • The right to be informed about how We use and store Your information
  • The right to access the personal information We store about You
  • The right to request the correction of inaccurate information, such as through the My Account section on Our Website
  • The right to opt-out of non-critical marketing activities on Flubit
  • The right to complain to Your data protection regulator

 

If You want to exercise Your rights, or have any questions or concerns please contact Us at talktous@flubit.com or visit Our data privacy page: http://flubit.com/account/privacy

 

Right to be forgotten

Users also have the legal right to request deletion of any personally identifiable information. We will adhere to this request where the deletion of information does not impact Our commitment to uphold any financial or legal requirements We must undertake to operate.

Requests must be responded to within 30 days, however requests which are overly complicated may take longer to process. To make any of the above requests, please contact Our dedicated customer support team at Customer Support

 

No Fee Usually Required

We do not anticipate that You will 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. Alternatively, we may refuse to comply with Your request in these circumstances.

 

We may need further data from You

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 personal data is not disclosed to any person who has no right to receive it.

 

 

 

 

  1. Change to Our privacy policy

 

We will make changes to Our Privacy Policy from time to time. You will be notified about these changes when they occur, and we will let You know a summary of the key changes. We do suggest however You always take time to read any changes before continuing to use Our service.  

 

  1. Cookies

 

We have a separate Cookie policy, this can be found at https://talktous.flubit.com/hc/en-us/articles/360004197974-Cookies-and-tracking 

 

 

 

 

 

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