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The Savings Group Privacy Notice

The Savings Group Limited (”we” “us” or “our”) operates the portal, including the coupon services, which can be accessed at coupons.stuff.co.nz (referred to as the “Portal” or “the Services”).

We take the protection of your personal information seriously and comply with the New Zealand Privacy Principles set out in the Privacy Act 1993. This privacy notice explains how we collected personal information and the purposes the data is used. This privacy notice also sets out your rights in respect of our use of your personal information.

1. What is the purpose of this Notice?

This privacy notice explains our approach to how we may use any personal information that you supply to us (or that we might collect from you) in connection with your use of the The Savings Group Services.

2. Who are we?

The Savings Group Limited is incorporated in England and Wales (Company No. 12263579) with registered office is at 4th Floor, Park Gate, 161-163 Preston Road, Brighton, East Sussex, BN1 6AF, United Kingdom.

3. How to contact us?

If you have any questions about this privacy notice or want to exercise your rights, please contact us by: sending an email to hello@thesavingsgroup.co.uk

4. What personal information do we collect and how do we collect it?

Personal information may be collected from you in the following ways:

  • Information about you that you voluntarily provide to us.

We collect and maintain personal information about you that you voluntarily submit to us during your use of the Services (e.g. if you register to use the Services, during the course of email exchanges with us or as part of any customer support interactions).

  • Information about you that is provided to us when you register or login with Facebook or other social media account.

If you register with Facebook or other social media account or otherwise connect or integrate this Service with your social media accounts, we may receive information relating to your social media accounts.  The integration transfers the public profile information (e.g., profile, name, e-mail address, age, occupation, place of residence, gender) specified by you, as well as your automatic account identification number that is stored by Facebook.

  • Information we collect through your use of the Portal.

We collect, through our use of cookies or other technologies, personal information regarding your use of the vouchers codes / coupons accessed via the Services and other otherwise in relation to your activity on the Services and in relation to the device or the computer hardware and software used to access and use the Services.

This personal information allows us to deliver the Services, understand the purchase journey including whether you completed a transaction at our retailer partners as well as providing more helpful information, recommendations and tools. Please see our cookie policy for further information.

  • Information we collect from third parties.

From time to time, we will receive personal information about you from third parties. Such third parties may include retailers where you redeemed a voucher, other users, analytics providers and third parties that provide technical services to us so that we can operate our service.

5. How do we use your personal information?

Our primary reasons for collecting personal information from you is to: (i) operate and provide the Services; (ii) track the usage of voucher codes / coupons and how and when they are redeemed by you to enable us to recover our commission from retailers (iii) verify your identity (where applicable); (iv) help us improve our Services and develop and market new products and services; (v) carry out requests made on our Services; (vi) investigate or settle enquiries or disputes; (vii) comply with applicable law, court order, other judicial process and the requirements of regulators; (viii) enforce our agreements with you; (ix) protect the rights, property and safety of us or third parties, including users of our Services; (x) provide support for the provision of our Services; (xi) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

  • Provision of the Portal and The Savings Group Service.

We need to use your information to track the usage of voucher codes / coupons and how and when they are redeemed, verify who you are, ensure you get the service that you require and otherwise fulfil your request / our agreement to provide you with services.

What is our legal basis?

It is necessary for the performance and fulfilment of the services / agreement between us and to provide you with access to vouchers codes / coupons.

  • Personalising content or providing recommendations.

We may personalise content and the Services or otherwise recommend content / vouchers / coupons or updates on any new features or content our Services.

What is our legal basis?

It is necessary for us to use the personal information to perform our obligations in accordance with any agreement that we may have with you, or it is in our legitimate interest to use personal information in such a way to ensure that we provide the Services requested by you and others in an effective and efficient way.

  • Serving adverts.

We use information that we observe about you from your interactions with our Service (see the Insight and Analysis section below for more details of the information collected and how it is collected) to provide you with personalised online advertising. We share your cookie data with a variety of third party service providers who assist us with our online personalised advertising campaigns. See our Cookie Policy for more info. We do not respond to or honour Do Not Track signals submitted by browsers.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

  • Insight and Analysis.

We analyse personal information and what we collect about you from your interactions with our services. This information is used to create insights about our visitors’ browsing habits on our service. Where we have your consent to do so, we will also use your location data for insight and analysis purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our services. This allows us to learn what content is most attractive to our visitors, which parts of our service are most interesting and what kind of features and functionalities our users like to see.

We use this information to help us with the selection of future content and service lines and design and to remember your preferences.

We also use this information for marketing purposes (see the “Marketing Activities” section below for further details).

Our legal basis for processing

Where personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute regulated personal information. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where personal information is not in an anonymous form, it is in our legitimate interest to use personal information in such a way to ensure that we provide good quality services to you and others.

Marketing activities.

  • Email, messages and SMS/MMS marketing.

We may use your name, mobile number or email address to send you marketing communications by email, message or by SMS/MMS. Our marketing communications may include information promoting the service, as well as general information about our organisation.

Our marketing may include personalised and non-personalised marketing.

Where we are sending you personalised marketing, we also use information that we observe about you from your interactions with our service and with our communications to you in order to decide what sort of personalised marketing communications to send you. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected.

Our legal basis for processing

We will only send you marketing communications by email or other electronic means where you have consented to receive such communications, or where we have another lawful right to send such communications to you.

  • Social media remarketing.

We use information that we observe about you from your interactions with our service, and with our communications to you to provide you with personalised advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is collected. We do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute regulated personal information. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook and/or Google respectively for marketing purposes.

  • Social media insight.

Where you are a registered user of Facebook or of a Google service, we may use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services who share similar interests to you based on:

information that we observe about you from your interactions with our service, and with our communications to you (see the “Insight and Analysis” section above for more details of the information collected and how it is collected); and
  the information Facebook and/or Google hold about you.
We do this using Facebook Lookalike Audiences and/or Google Similar Audiences respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

Our legal basis for processing

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute regulated personal information. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
  Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

  • Running competitions and/or promotions.

We may collect and use your personal information in connection with any competition and/or promotion we decide to run.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to operate the promotion and/or competition.  Please note that we will only send you marketing communications about a competition or promotion with your consent.

  • Surveys and feedback.

We may invite you to provide feedback about us in survey or other means. We will collect and process your name and contact details and any other personal information you choose to volunteer in your survey response or other feedback. We use this information to help us improve the quality of service provided by our personnel.

Our legal basis for processing

It is in our legitimate interest to use the personal information provided by you in your feedback you submit for the purposes described above.

  • Service Administration.

We may also use your personal information to:

     
  • help improve the Services; and
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  • send you administrative e-mails or contact you to answer any queries you may have sent to us.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

     
  • to comply with our legal obligations;
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  • to enforce our legal rights;
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  • to protect the rights of third parties; and
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  • in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Our legal basis for processing

Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

6. Sharing personal information

We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal information, we may need to share it with third parties as follows:

Retailers, publishers or other affiliate networks: We share personal information with such third parties in order to operate and provide the Services including to track the usage of voucher codes / coupons and how and when they are redeemed by you.
  Third-party organisations that provide applications/functionality, data processing or IT services: We share personal information with third parties who support us in providing our Services and help provide, run and manage our internal IT systems.

For example:

Website hosting providers: We share personal information with third parties who supply us with hosting or other technology services.

Third-party email marketing and CRM specialists: We share personal information with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.

Third-party organisations that assist us with the administration of our promotions: We share personal information with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.

Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies: We share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and to provide our Services.

Any third parties that we share your information with as above will be strictly limited to using your data strictly on our instruction and solely to fulfil a service for us to enable us to provide the Services to you.

7. How do we obtain your consent?

Where use of your personal information by us requires your consent, you can provide such consent:

     
  • at the time we collect your personal information by following the instructions we give such as ticking a box on a registration form; or
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  • by informing us using the email address set out in this privacy notice.

8. Use of cookies

The Services use various cookies and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

9. Third Party Links and Services

The Services may contain links to third party websites and services. Please remember that when you use a link to go from the Services to another website or you request a service from a third party, this privacy notice no longer applies.

Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.  We do not monitor, control, or endorse the privacy practices of any third parties.

10. Transfers outside the EEA

The Savings Group Limited is based in the UK. In order to operate our Services, when you give us personal information, this will be transferred to countries outside the EEA, including to the UK in the event the UK leaves the EU.

Non-EEA countries do not have the same data protection laws as the EU and may not provide the same degree of protection for your personal information.

Other third parties that we share your personal information with – as described in section 6 above, may also be based outside of the EEA. However, when transferring your personal information to these sub-processors outside the EEA, we will comply with our legal and regulatory obligations in relation to your personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

11. How long do we keep your personal information for?

We do not keep your personal data for any specific period, but will not keep it for longer than is necessary for our purposes.

In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.

12. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide us or we collect secure and we will take reasonable precautions to protect it from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Services.

13. How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you:

Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability.

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we’re:

  • relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
  • processing your personal information for direct marketing; or
  • processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, an agreement between you and us.

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

14. Change to this privacy notice

We may make changes to this privacy notice from time to time.

To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.

Last updated: 1 December 2019