SUMMARY

 

We take your right to privacy very seriously and so, before you download the Ganddee app or use our website, please take a moment to read how we collect and use your personal data.

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Why do we need your personal data?

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We need to collect this information about you when you sign up and each time you use the App so that you can get the most out of Ganddee. We do not collect special category personal data such as any medical details and criminal records. We store your personal data securely. You have consented to provide this information to us but can withdraw your consent at any time by getting in touch with us (hello@ganddee.com).

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What do we do with your personal data?

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We retain your personal data only for as long as necessary to carry out the functions of the App. If you notify us that you no longer wish to be listed on the database, we will delete your information as soon as possible.

We use your personal data to provide you with information about shops nearby.

We may use your personal data to contact you about Ganddee services that we believe you may be interested in. We do not share your personal data with anyone unless we are required to do so by law or when it is necessary to make the App run smoothly.

We do not sell your personal data to anyone.

All the personal data that we process is located on servers within the UK, the European Economic Area (EEA) or the United States of America.

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What are your rights?

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You have a right to request a copy of your personal data and/or you can request that your personal data be deleted by making a request to hello@ganddee.com. If, at any point, you believe the personal data we process on you is incorrect, you can request to have it corrected. If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter. There are more details on your rights set out in our full Privacy Policy below.

 

PRIVACY POLICY

 

Last updated: 25 July 2023

 

1. Introduction

 

This privacy policy should be read alongside, and in addition to, our Terms of Use (the ”Terms”), which can be found at: https://ganddee.com/terms

Any capitalised terms which are used in this privacy policy but are not defined shall have the same meaning set out in the Terms.

 

Please read this privacy policy carefully.

 

Bluteshi Ltd (“us”, “we”, the “Company”, “Bluteshi” or “Ganddee”) respect your (“you” or “User”) privacy and are committed to protecting it through our compliance with this policy.

For the purposes of this policy both the website www.ganddee.com/ and the Ganddee application shall be referred to as the “App”.

This policy applies only to information we collect on the App, via email, text and other electronic communications sent through or in connection with the App.

 

This policy does not apply to information that:

• we collect offline or on any other Company apps or websites (other than www.ganddee.com/), including websites you may access through this App; or

• you provide to or is collected by any third party (see “Third-party information collection”) unless this information is provided by them to us.

 

Please note, we may have a separate privacy policy for our other websites and apps and third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

If you do not agree with our policies and practices, do not download, register with or use this App. By downloading, registering with or using this App and, where applicable, ticking our consent boxes, you agree to this privacy policy. This policy may change from time to time (see “Changes to our privacy policy”). Unless such changes mean changes to your preferences, your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Users under the age of 16: the App is not intended for anyone under 16 years of age, and we do not knowingly collect personal data from anyone under 16. If we learn we have collected or received personal data from anyone under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a user under 16, please contact us at: hello@ganddee.com.

 

2. Identity of Data Controller

 

A data controller is a person or organisation who makes decisions about how your personal data is collected, used and handled. The Company is the data controller and may be contacted:

• by post: Bluteshi Ltd, Silverstream House 45 Fitzroy Street, 4th Floor, Fitzrovia, London, England, W1T 6EB; and

• by email: hello@ganddee.com

 

3. What information is collected

 

We collect personal data from and about users of our App (“Data”):

• directly from you when you provide it to us; and

• automatically when you use the App.

 

We do not collect special categories of personal data such as information relating to or about the below:

• Health

• Racial or ethnic origin

• Political opinions

• Membership of a political association, professional or trade association

• Membership of a trade union

• Religious beliefs or affiliations

• Philosophical beliefs

• Sexual orientation or practices

• Biometric information

• Criminal records

 

Data that you provide to us when you download, register with or use this App may include:

• First name and last name

• Postal address

• Email address

• Telephone number

• Profile picture

• Display name

 

​If you choose to upload a profile picture, please be aware that this image is publicly visible to other Ganddee users. While we reserve the right to remove inappropriate images, Ganddee is not responsible for the content of user-selected profile pictures.

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In addition, we may collect other information that is about you but individually does not identify you, such as age or gender.

 

Data may also include:

• information that you provide by filling in forms in the App such as first name, last name, email address, telephone number and address. This includes information provided at the time of registering to use the App and requesting/signing-up for further services;

• information when you enter a contest or promotion sponsored by us;

• information that you provide when you complete user surveys or surveys for research purposes;

• information you provide to us when you report a problem with the App;

• records and copies of your correspondence when you contact us; and

• details of transactions you carry out through the App and of the fulfilment of your orders;

 

Third-party information collection. When you use the App or its content, certain third parties may use automatic information collection technologies to collect personal data about you or your device. These third parties may include:

• Advertisers, affiliate advertisers, ad networks and ad servers;

• Analytics companies;

• Your mobile device manufacturer; and/or

• Your mobile service provider.

 

These third parties may use tracking technologies to collect information about you when you use the App. The personal data they collect may be associated with your Data or they may collect information about your online activities over time and across different websites, apps and other online services or websites. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

For information about how you can opt out of receiving targeted advertising from many providers, see section 8 below.

 

4. How Data is collected

 

Automatic Data collection and tracking. When you download, access and use the App, it may use technology to automatically collect:

• Usage details: when you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the App.

• Device information: we may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.

• Stored information and files: the App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information. You will be asked for your consent to such access and use of your Data within the App. You can withdraw your consent at any time via the settings menu.

• Location information: the App collects real-time information about the location of your device. We do not, however, continually collect user location data nor do we collect location data without the user being aware. We store the location of a user at set points, for example when you choose to update your location on the map. Some of our location-enabled services require your Data for the feature to work. You will be asked for your consent to such access and use of your Data within the App. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled. You can withdraw your consent at any time via the settings menu.

 

If you do not agree to us collecting this information, please do not create an account with us. We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking).

 

The technologies we use for automatic Data collection may include:

• cookies (or mobile cookies): a cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting you may be unable to access certain parts of our App.

• the cookies we use include:

  • Strictly necessary cookies: these are required for the operation of our App. They include, for example, cookies that enable you to log into secure areas of our App.

  • Analytical/performance cookies: these allow us to recognise and count the number of visitors on and to see how visitors move around the App when they are using it. This helps us to improve the way our App works, for example, by ensuring that users are finding what they are looking for easily. These cookies are used to collect information about how visitors use our App. We use the information to compile reports on general user traffic, conversion statistics and to help us improve the App. These cookies collect information anonymously.

  • Web Beacons: pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).​

  • Functionality cookies: these are used to recognise you when you return to our App. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the App, you agree to our placement of functionality cookies.

  • Targeting cookies: these record your visit to our App, the pages you have visited and the links you have followed. We will use this information to make our App and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

  • Third-party cookies: the App may link to other websites owned and operated by certain trusted third parties who, for example, collect data that helps us track conversions from ads. These other third-party websites may also use cookies or similar technologies in accordance with their own separate policies. Please note that our advertisers may also use cookies, over which we have no control. For privacy information relating to these other third-party websites, please consult their policies as appropriate.

• Third-party software/services. We use third-party software/services to collect and process your personal data in order to provide you with a great discovery experience on Ganddee. Some of these services are:

  • Google Firebase services: including Crashlytics, Firebase

  • Mixpanel: Collects device information to be used to solve product issues

  • Amazon AWS: Logs, performance, debugging

  • Sentry: Error and system performance monitoring

  • Google Analytics: Feature usage and acquisition channel reporting

 

5. How we use Data and lawful basis for processing

 

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our App. Specifically, Data may be used by us for the following reasons:

• internal record keeping;

• improvement of our products / services;

• transmission by email of marketing materials that may be of interest to you;

• contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the App, in each case, in accordance with this privacy policy.

 

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see section 9 below).

 

For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

• soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.

• for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide in the registration process.

 

If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We use your Data to:

• set up and operate your Ganddee account (such processing is necessary for the performance of our contract with you).

• verify your identity and carry out security checks in order to set up your account (such processing is necessary for the performance of our contract with you and necessary for us to comply with a legal obligation).

• provide you with the App and its contents, and any other information, products or services that you request from us (such processing is necessary for the performance of our contract with you).

• give you notices about your account, including expiration and renewal notices (such processing is necessary for the performance of our contract with you and necessary for us to comply with a legal obligation).

• ensure that content from our App is presented in the most effective manner for you and for your computer or device for accessing the App (such processing is necessary for the performance of our contract with you).

• carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (such processing is necessary for our legitimate interests (to recover monies due, etc)).

• notify you when App updates are available, and of changes to any products or services we offer or provide through it (such processing is necessary for our legitimate interests (to allow us to provide changes to our software, products or services)).

• collect information from surveys that you sign up to take part in (such processing is necessary for our legitimate interests - to improve our services).

• manage your account, including processing payments and refunds and providing notifications, should this service be introduced within the App (such processing is necessary for the performance of our contract with you and is necessary for our legitimate interests - to process payments).

 

The usage information we collect helps us to improve our App and to deliver a better and more personalised experience by enabling us to:

• estimate our audience size and usage patterns (such processing is necessary for our legitimate interests - for running our services and to study how users use our App).

• store information about your preferences, allowing us to customise our App according to your individual interests (such processing is necessary for our legitimate interests - for running our services).

• speed up your searches (such processing is necessary for our legitimate interests - for running our services).

• recognise you when you use the App (such processing is necessary for the performance of our contract).

• provide us with information about how the App is running or whether there are any faults or issues with our products and services (such processing is necessary for our legitimate interests - for us to deliver a better service to you).

 

We use location data to:

• provide information about listed shops within a fixed distance from the user’s set location (such information is necessary for the performance of our contract with you).

• help you find your way to listed shops on Ganddee (such information is necessary for the performance of our contract with you).

 

6. Keeping Data secure

 

We have implemented reasonable measures designed to secure your Data from accidental loss and from unauthorised access, use, alteration and disclosure, for example:

• access to your account is controlled by a password and a username that is unique to you; and

• we store your Data on secure servers.

 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Data, we cannot guarantee the security of your Data transmitted through our App. Any transmission of Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

If you suspect that there has been a breach of the security of your data you should contact us at: hello@ganddee.com and include details of the nature, the date and the full circumstances of the breach.

On notification of such a breach, we will investigate the matter and, where appropriate and required by law, notify the relevant data protection regulator.

 

7. How personal data is shared and with whom

 

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose Data that we collect or you provide:

• to our subsidiaries and affiliates.

• to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Data confidential and use it only for the purposes for which we disclose it to them.

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Data held by the Company about our App users is among the assets transferred.

• to fulfil the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our App, we will transmit the contents of that email and your email address to the recipients.

• for any other purpose disclosed by us when you provide the information.

• for the purposes of academic research.

• for any other purpose with your consent.

• to comply with any court order, law or legal process, including to respond to any government or regulatory request.

• to enforce our rights arising from any contracts entered into between you and us.

• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

8. What choices you have with respect to how personal data is used

 

We strive to provide you with choices regarding the Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information. You may need to adjust the settings on your device to restrict the collection of information by the App but this may prevent you from accessing all of the features of the App.

• Tracking Technologies: you may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

• Location Information: you can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly. For example, users have the ability to only allow manual geolocation (rather than using their device’s auto-locating functionality), the provision of at least one piece of location data (i.e. the user’s search location) is a requirement for the App to function.

• Promotion by the Company: if you do not want us to use your email address or other Data to send you information, notifications, news, surveys or promote our own products or services, you can opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to hello@ganddee.com.

• Targeted advertising by the Company: we do not use information that we collect or that you provide to us to deliver our own advertisements.

• Disclosure of your information for third-party advertising and marketing: we do not share your Data with third parties for advertising and marketing purposes. However, we may include offers from third parties in our marketing materials and via links or pop-ups in the App.

 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. Note: In the United States of America you can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

 

9. Your rights with respect to personal data

 

You have the following rights in relation to your Data:

• Right to access: the right to request copies of the Data we hold about you at any time. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

• Right to correct: the right to have your Data rectified if it is inaccurate or incomplete.

• Right to erase: the right to request that we delete or remove your Data from our systems.

• Right to restrict our use of your Data: the right to “block” us from using your Data or limit the way in which we can use it.

• Right to data portability: the right to request that we move, copy or transfer your Data.

• Right to object: the right to object to our use of your Data, including where we use it for our legitimate interests.

 

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data, please contact us via this e-mail address: hello@ganddee.com.

 

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

We will respond to a request to access, correct or delete any data within 30 days of the date we receive the request.

We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect.

 

10. How long personal data is kept?

 

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Upon deletion of an account, all Data will be removed as soon as possible, and always within 90 days of the deletion.

 

11. Changes to this privacy policy

 

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ Data, we will notify you by email or via the App. By continuing to use the App after notification, you will be deemed to have accepted any changes.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

 

12. Information

 

All questions, comments and requests regarding this privacy policy should be addressed to the contact details as set out in the App and on www.ganddee.com or by email to hello@ganddee.com.

 

13. Links to other websites

 

This App may provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

 

14. General

 

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

 

15. Changes of business ownership and control

 

Ganddee may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Ganddee. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

 

16. Transfers outside the United Kingdom and European Economic Area

 

Data which we collect from you may be stored and processed in and transferred to selected countries outside of the UK and European Economic Area (EEA). For example, this could occur where our servers or one of our service providers are located in a country outside the UK or EEA, such as the United States of America.

We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, eg. by way of data transfer agreement.

To ensure that your Data receives an adequate level of protection, we select the third parties we share your Data with very carefully and ensure their data protection safeguards and procedures are of standards equivalent to those applicable in the UK or EEA.