Introduction
Welcome to the CarryBags Ltd of UK Inc, CarryBags Limited is (known individually or collectively as “CarryBags”) privacy notice.
CarryBags respects your privacy and is committed to protecting your personal
data. This privacy notice will inform you as to how we look after your personal
data when you visit our website (regardless of where you visit it from) or
otherwise provide data to us offline in the course of our dealings with you and
tell you about your privacy rights and how the law protects you.
This Privacy Policy is subject to local laws and may be adjusted from time to
time to comply with these requirements.
Important information and who we are:
Purpose of this privacy notice
This privacy notice aims to give you information on how CarryBags collects and
processes your personal data through your use of the App, website or Point of
Sale (POS) device in a CarryBags partner store including any data you may
provide through this website when you sign up to our newsletter, purchase the CarryBags
service or take part in a competition or when we take your details (collect
your personal data) offline in order to provide services to you. ANY
INFORMATION THAT IS COLLECTED VIA OUR SERVICES IS COVERED BY THE PRIVACY POLICY
IN EFFECT AT THE TIME SUCH INFORMATION IS COLLECTED. WE MAY REVISE THIS
POLICY FROM TIME TO TIME. IF WE MAKE ANY MATERIAL CHANGES TO THIS POLICY,
INCLUDING ANY CHANGE THAT WE PROPOSE WILL HAVE RETROACTIVE EFFECT, WE’LL NOTIFY
YOU OF THOSE CHANGES BY POSTING THEM ON THE WEBSITE OR THE APP OR BY SENDING
YOU AN EMAIL OR OTHER NOTIFICATION, AND WE’LL UPDATE THE “LAST UPDATED DATE”
BELOW TO INDICATE WHEN THESE CHANGES WERE MADE.
The CarryBags Service, App, POS device and website is not intended for children
and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other
privacy notice or fair processing notice 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 notice supplements
the other notices and is not intended to override them.
Controller
CarryBags Limited is the controller and responsible for your personal data
(collectively referred to as “Carrybags”, "we", "us" or
"our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about
this privacy notice, including any requests to exercise your legal rights,
please contact the data privacy manager using the details set out below.
Contact details
Our full details are:
Full name of legal entity: Carrybags Limited
Email address: support@wecarrybags.co.uk.
Postal address: The Enterprise Hub 5, Whitefriars Street, CV1 2DS,
Coventry United Kingdom
Telephone number: +44 7388434934
Depending on your jurisdiction and where you use the CarryBags Services, you have the right to make a complaint at any time to make a complaint to any relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before this so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in December 2021 and historic versions can be
obtained by contacting us.
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
Our website may include links to third-party websites, plug-ins and
applications. Clicking on those links 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. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.
1. The data we collect about you
Personal data, or personal information, 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, delivery address, email address and telephone numbers.
· Financial Data includes bank account and payment card details. This type of personal data is currently collected and stored by a third party.
· Transaction Data includes details about payments to and from you and other details of services you have purchased from 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 our 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, products and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, your Contact Data as relevant to provide you with marketing information in accordance with any preferences or as provided in accordance with the law.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
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 CarryBags services). In this case, we may
have to cancel a service you have with us but we will notify you if this is the
case at the time.
2. 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, Marketing Data and Financial Data by filling in forms or by corresponding with us by post, phone, email, via the App or otherwise. This includes personal data you provide when you:
· apply for our or services;
· create an account on our App, POS device, website or with us directly;
· subscribe to our service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback.
Automated technologies or interactions. As you interact with our website, we
may 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. Please see our cookie for further
details.
Third parties or publicly available sources. We may receive personal data about
you from various third parties as set out below:
· Technical Data from the parties such analytics providers Google, based outside the EU;
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
3. 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.
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 or regulatory obligation.
· Legitimate Interest means 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
· Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
· Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
· Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
Where you have consented to our use of your personal data for specific
purposes;
· Consent means you have expressly given us consent to process your personal data for specific purposes such as to process your data for marketing purposes or supply you with third party direct marketing communications to you via email or text message. You have the right to withdraw consent you have given at any time, however, where you do this in respect of processing information to provide our services to you we will no longer be able to fulfil this.
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly relating to marketing and advertising. We do not sell your
personal data.
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 or purchased services from us or if you provided us with
your details when you entered a competition or registered for a promotion and,
in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with
any company outside the CarryBags group of companies for marketing
purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any
time by sending us a message via in-app live chat, calling us by phone or
sending us an email or by clicking ‘Unsubscribe’ in our emails.
Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a service purchase, service
experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our cookie
statement.
Change of purpose
We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or
consent, in compliance with the above rules, where this is required or
permitted by law.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the
purposes outlined in paragraph 3 above.
· Internal Third Parties as set out in the Schedule.
· External Third Parties as set out in the Schedule.
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.
5. International transfers
We share your personal data within the CarryBags group of companies. This will
involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area
(EEA) so their processing of your personal data will involve a transfer of data
outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the
following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. If there is no adequacy decision in place from the European Commission with a third country then we will take all steps to ensure that such a transfer of your personal data is done with appropriate protection in place, using the Standard Contractual Clauses where necessary. Please be advised that if you are an EU citizen using our services, your data will be transferred to the UK and such transfers are subject to the Data Protection Act 2018, which ratified GDPR in the UK and also to the SCCs as set out in the Guest Terms and Conditions.
· Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
· Where we use providers based in the US, we may transfer data to them provided we have put in place adequate measures to provide your Personal Data with the same level of protection required by GDPR or the Data Protection Act 2018.
· Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. 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. 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. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider
the amount, nature, and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
In accordance with certain laws to which the CarryBags Limited is subject, 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 audit purposes.
In some circumstances you can ask us to delete your data: see “Request erasure”
below for further information.
In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. We do not sell or share your personal data.
However you may still specifically opt out of the sale of your personal
data by clicking on the attached link: Do not sell my personal Data
You have the right at any time to:
Request access to your personal data (commonly known as a "data subject
access request"). This enables you to receive a copy of the personal data
we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables
you to have any incomplete or inaccurate data we hold about you corrected,
though we may need to verify the accuracy of the new data you provide to
us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the
time of your request.
Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.
Request restriction of processing of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following
scenarios: (a) if you want us to establish the data's accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate
grounds to use it.
Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at support@wecarrybags.co.uk
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. Alternatively, we may refuse to
comply with your request in these circumstances.
What we may need 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. We may also
contact you to ask you for further information in relation to your request to
speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.
Schedule
Internal Third Parties
Other companies in the CarryBags group acting as joint controllers or
processors and who are based EEA, USA and provide IT, Research and Development
and system administration services and undertake leadership reporting.
External Third Parties
The parties with whom we may share your data will vary depending (for example
courier providers) depending on where you use the CarryBags Services, and we
will not share your data with any party that does not need to receive it in
order to effect delivery of the Services
Service providers acting as processors based in USA and the EEA who provide IT,
system administration and delivery services:
AppsFlyer Ltd. - https://www.appsflyer.com/product/gdpr
Intercom, Inc. and Intercom R&D Unlimited Company - https://www.intercom.com/security
Stripe, Inc. - https://support.stripe.com/questions/stripe-and-european-data-transfers
Google Inc. (Google Cloud and Google Analytics) - https://cloud.google.com/security/gdpr/,https://policies.google.com/privacy?hl=en
MongoDB, Inc. - https://www.mongodb.com/cloud/compliance/gdpr
Apple Inc. - https://www.apple.com/legal/privacy/en-ww/governance/
Microsoft Corporation - https://www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/default.aspx
Facebook, Inc. and Facebook Ireland Ltd. - https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr
Other external third parties:
Professional advisers acting as processors or joint controllers including
lawyers, bankers, auditors and insurers based EEA, who provide consultancy,
banking, legal, insurance and accounting services.
Relevant national regulators and other authorities acting as processors or
joint controllers based in jurisdictions where CarryBags operates or has a
presence who require reporting of processing activities in certain
circumstances.