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Privacy and Cookie Policy (March 2022)

  1. Introduction

    1. VEEIP Limited (us, we) takes your privacy very seriously. We ask that you read this Privacy & Cookie Policy carefully as it contains important information about what to expect when we collect personal information about you and how we will use your personal data.
    2. This policy should be read in conjunction with the VEEIP Member Terms and Conditions which together with this policy form the terms of the Agreement between us and you as a participant in the VEEIP Platform. Defined terms used in this policy which are not defined below have the meanings given to them in the VEEIP Member Terms and Conditions.
    3. By agreeing to the Agreement you are giving us your express permission for us to collect and process the information and to share it with the third parties, in both cases for the limited purposes as set out below.
    4. VEEIP Limited is a limited company registered in England and Wales with registration number 06588217 and with its registered office at 20-22 Wenlock Road, London, N1 7GU.
    5. This policy applies to information we collect about individuals who participate in the VEEIP Platform through our website veeip.com and mobile/other device applications or 'Apps'.
  2. The information we collect about you

    1. When you register as a Member we collect the following personal information from you:
      1. name;
      2. postcode, email address, mobile number;
      3. gender and date of birth;
      4. city and country of residence; and
      5. other information relating to your preferences and interests used for engagement and personalisation purposes.
    2. In order for your purchases at Brands, Places and Events and your membership of Crowds to be counted towards your qualification for Rewards, you will need to link your Account to the payment methods that you already use. When you do, we will collect the following personal information from you in relation to each payment method:
      1. payment method identification number, e.g. the long number on your payment card;
      2. expiry date; and
      3. whether it is a personal or business account.
    3. We reserve the right to validate your payment methods ourselves or with third parties in order to verify that they belong to or are controlled by you, although we may not do this on every occasion and this does not affect your duty to provide complete and accurate information to us.
    4. If you do not have an active personal payment method associated to your Account, you may need to provide the details of a UK bank account in order to receive Reward payments, in which case we will collect the following details:
      1. bank name;
      2. account name; and
      3. account number and sort code.
    5. The data referred to in clauses 2.1 to 2.4 above is Member Data.
    6. The VEEIP Platform allows you to affiliate with one or more Brands, Places, Events and Crowds and to initiate campaigns to encourage other businesses or entities to join the VEEIP Platform, or to vote or comment upon campaigns initiated by other users. When you do so, we will collect and record your affiliation, campaign or voting preference.
    7. We will receive payment information from organisations who operate Brands, Places and Events in the VEEIP Platform (or third parties on their behalf). If you engage in transactions of any kind (including purchases and refunds) with a linked payment method at a participating Brand, Place or Event, we will match it in the payment information we receive. We will generate and record the following data about you:
      1. the Brand (including the specific outlet, concession or franchise owner if applicable), Place or Event at which the transaction took place;
      2. the time and location of the transaction;
      3. the value of the transaction; and
      4. any other information available from time to time that we may use to enhance your experience within the VEEIP Platform.
    8. We will receive information from organisations who operate Crowds in the VEEIP Platform relating to your membership of such organisations or other eligibility criteria to join Crowds within the VEEIP Platform.
    9. The data that we collect and generate in clauses 2.6 to 2.8 above is Member Activity Data.
  3. How we will use the information about you

    1. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
      1. to comply with our legal and regulatory obligations;
      2. for the performance of our contract with you or to take steps at your request before entering into a contract;
      3. for our legitimate interests or those of a third party; or
      4. where you have given consent.
    2. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
    3. The following paragraphs explain what we use (process) your personal information for and our reasons for doing so (which in all cases unless stated otherwise are for the performance of the contract between us set out in the VEEIP Member Terms and Conditions and/or where you have given consent).
    4. We gather the Member Data to allow us to process your registration and to allow you to participate in the VEEIP Platform. We gather and generate the Member Activity Data in the course of providing the VEEIP Platform benefits to you relating to your activity with Brands, Places, Events and Crowds.
    5. The relevant information from the Member Data and the Member Activity Data is used by us to deliver the VEEIP Platform and specifically for the following:
      1. to create an Account for you;
      2. to keep you updated as to our progress in creating your Account or administering the VEEIP Platform (pursuant to your stated notification preferences);
      3. in anonymised, aggregated data for general marketing and other purposes, which may be shared with third parties but will not be traceable to you or any other individuals;
      4. to match the transactions you make at your affiliated Brands or at the Places or Events that you attend;
      5. to match your transactions at Brands, Places, or Events that you have not previously affiliated with and to auto-affiliate you with them, which you may cancel in the VEEIP Platform. We will only auto-affiliate you once for each Brand, Place, or Event;
      6. to match and show you within the VEEIP Platform all transactions you make with Brands, Places, Events or Partners or as part of a Crowd within the VEEIP Platform, allowing you to choose whether to affiliate with them and see the VEEIPs you could be receiving;
      7. to tailor the VEEIPs you receive from Brands, Places and Events or through membership of Crowds, according to your preferences, demographic information and your transaction history; and
      8. to match your Member Data with Partners to identify a customer record within the Partner's own systems.
    6. We will share certain of your Member Data and Member Activity Data with your affiliated Brands and with any Places, Events or Crowds at which your Member Activity Data is collected. Please note that this may include us sharing your information with: (i) third party outlet, concession or franchise holders operating under licence from the Brand at the specific locations at which the purchases or VEEIPs take place; (ii) the businesses who own or operate the Brands, Places, Events or Crowds; and/or (iii) the businesses which own or licence the Brands, Places, Events or Crowds in the UK. We will not share your full name, email address or full postcode, but we will share your first name and last initial and the approximate location of your home address together with demographic information and your transactions with the Brand, Place or Event that are captured in the VEEIP Platform. You can cancel affiliations at any time.
    7. We may use certain elements of your Member Data and Member Activity Data to share whether you are already a customer of any of our Partners and potential Partners.
    8. If you make purchases using your linked payment methods at Brands, Places or Events that you have never affiliated to or where you have removed a previous affiliation (including a system-generated auto-affiliation), we will disclose limited and anonymous transaction, location and demographic information to those Businesses to help them understand a little more about their customers, visitors or attendees (as the case may be). We do not share your name, email address or full postcode, and instead refer to you by an anonymous reference.
    9. We may also use aggregate information and generate statistics for the purposes of monitoring VEEIP Platform usage or Member spending activity at Brands, Places, Events and Crowds in order to help us to develop the VEEIP Platform and recommend VEEIPs to Partners. We may also provide such aggregate information to the Partners and other third parties. These statistics will not include information that can be used to identify you.
    10. Transaction Monitoring. If you choose to register a payment card in the VEEIP Platform, you authorise us to share your payment card information with the card network (for example Mastercard, Visa or American Express) so it knows you enrolled. You authorise the card network to monitor transactions on your registered card(s) to identify qualifying purchases, and for the card network to share such transaction details with us to enable your card-linked offer(s) (VEEIPs) to be implemented, and to target other offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered using the VEEIP Platform by deleting it/them from your Account.
    11. We may collect and use technical information about the devices that you use to access the VEEIP Platform and related software, hardware and peripherals to improve the VEEIP Platform and the delivery of the VEEIPs to you.
    12. This section 3 sets out the entirety of our use and disclosure of your data. We only use it in the context of providing the VEEIP Platform to you and we will not share or sell your data for any other purposes.
  4. Marketing

    1. We may wish to provide you with information about special features of the VEEIP Platform or any other related service or products we think may be of interest to you. The VEEIP Platform gives you complete control as to whether and by what method(s) you receive these messages from us. You can change your preferences at any time using the VEEIP Platform.
  5. Our use of cookies and other information-gathering technologies

    1. A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies and other online tracking devices such as single-pixel gifs on this website to:
      • keep track of your activity on the website and as a member participating in the VEEIP Platform;
      • recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);
      • obtain information about your preferences, online movements and use of the internet;
      • carry out research and statistical analysis to help improve our content, products and services, to help us and the participating Brands improve the VEEIPs and other offers made to members, and to help us better understand our members' and other website visitors' requirements and interests;
      • target our VEEIPs and other marketing and advertising campaigns and those of participating Brands and tailoring your experience in the VEEIP Platform more effectively by providing interest-based VEEIPs and other offers that are personalised to your interests; and
      • make your online experience more efficient and enjoyable.
    2. The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances we may collect personal information about you—but only where you voluntarily provide it, for example by creating a VEEIP membership account or completing an online form.
    3. In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (see 'sess' cookie below).
    4. There is a notice on our home page which describes how we use cookies and which also provides a link to this policy. If you use this website after you have been informed about this notification and provided with a link to it, we will assume that you consent to our use of cookies for the purposes described in this policy.
    5. The table below provides more information about the cookies we use and why:
      • Session cookies are deleted when you leave our websites. They help keep track of your progress so you don't have to enter the same information more than once.
      • Persistent cookies stay on your device after your browsing session has ended. They will remember settings, preferences and details for the next time you use the websites.
      • First party cookies are set by us, the website owner, i.e. VEEIP.
      • Third party cookies are set by other parties, such as Google Facebook, Twitter, YouTube and Adobe Flashplayer which we may use to display video content. These third party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.
      • Necessary cookies are required for the operation of our website.
      • Performance or analytical cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
      • Functionality cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, for example, by remembering your preferences or Brands you are affiliated too.
      VEEIP cookies
      sessSession cookieRequired to access any content limited to logged-in only users
      csrfCross-Site Request Forgery Prevention cookie.
      veeipPersistentNon secure informational VEEIP cookie
      Google cookies
      google analytics
      . _gat: request rate throttle
      . _ga: used to distinguish users
      . _gid : used to distinguish users
      Persistent, Third party
      This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (eg how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had. The data stored by these cookies can be seen only by the relevant teams at VEEIP and Google and never shows any confidential information. For more information about how Google may use this data - visit this link
      Cloudflare cookies
      . _cfduuid: used to distinguish usersPerformance
      Persistent, Third party
      Helps Cloudflare detect malicious visitors to and minimizes blocking legitimate users.
      For more information, visit this link
    6. How to turn off cookies
      If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.
      For further information about cookies and how to disable them please go to the Information Commissioner's webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.
      For further information about cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
  6. How we protect your information

    1. We have put in place appropriate security procedures and technical and organisational measures to safeguard your personal information. These include:
      1. your personal data is encrypted and stored in a secure data centre which complies with the ISO 27001 and ISO 9001 standards;
      2. we do not collect all the information about your payment methods that would be required in order to instruct payments to be made against them; and
      3. required payment method details are entered by you into the secure pages of the VEEIP Platform; we will never ask for payment card or device details over the telephone or any other method of communication save for the limited information requested in the VEEIP Platform.
    2. Our systems comply with the PCI DSS regulations. The Payment Card Industry Data Security Standard (PCI DSS) has been developed to encourage and enhance the security of payment cards (e.g. debit cards and credit cards). The PCI DSS is adopted by the leading banks, card issuers and payment service providers in the United Kingdom and throughout the world. Further details of the PCI DSS can be found at: https://www.pcisecuritystandards.org/.
    3. We use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.
  7. Overseas transfers

    1. The information you provide may be transferred to IT and administrative services suppliers in countries outside the UK that do not have similar protections in place regarding your data and restrictions on its use. However, if and when we need to do so, we will take steps to ensure adequate protections are in place to ensure the security of your information, including the use of standard contractual clauses. By submitting your information you consent to these transfers for the purposes specified above.
  8. Access to your information and updating and correcting your information

    1. You may access any of the information that we hold about you by accessing your Account in the VEEIP Platform. Alternatively, if you would like a copy of some or all of your personal information, please send an email to [email protected]. We may make a small charge for this service.
    2. We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address, name or linked account details, or if you wish to cancel your registration, please update your details promptly by accessing your Account in the VEEIP Platform. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
    3. We shall retain your data as long as your Account remains active and for a period of 6 years after termination of your account.
  9. Sale of business

    1. If our business is sold or integrated with another business by virtue of an asset sale your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business in order to continue provision of the VEEIP Platform to you.
  10. Your consent

    1. By submitting your personal information you consent to the use of that information as set out in this policy.
  11. Changes to privacy & cookie policy

    1. We keep our Privacy & Cookie Policy under regular review. If we change our Privacy & Cookie Policy we will notify you in the VEEIP Platform, so that you may be aware of the information we collect and how we use it at all times. This Privacy & Cookie Policy was last updated on 14th March 2022.
  12. How to contact us

    1. We welcome your views about our VEEIP Platform and our Privacy & Cookie Policy. If you would like to contact us with any queries or comments please us the Contact Us sections of the VEEIP Platform.
  13. Links to other websites

    1. Our VEEIP Platform contains links to other websites. This Privacy & Cookie Policy only applies to the VEEIP Platform so when you access links to other websites you should read their own privacy policies.
  14. Your rights

    1. You have the following rights, which you can exercise free of charge:
      AccessThe right to be provided with a copy of your personal information (the right of access)
      RectificationThe right to require us to correct any mistakes in your personal information
      To be forgottenThe right to require us to delete your personal information - in certain situations
      Restriction of processingThe right to require us to restrict processing of your personal information - in certain circumstances, e.g. if you contest the accuracy of the data
      Data portabilityThe right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
      To object The right to object:
      - at any time to your personal information being processed for direct marketing (including profiling);
      - in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests
      Not to be subject to automated individual decision-makingThe right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
    2. 14.2 For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner's Office (ICO) on individuals' rights under the General Data Protection Regulation.
      If you would like to exercise any of those rights, please:
      1. Contact us via the VEEIP Platform; and
      2. let us have enough information to identify you, e.g. your full name, address and VEEIP Platform user name;
      3. we may request proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
      4. let us know what right you want to exercise and the information to which your request relates.
    3. How to complain
      We hope that we can resolve any query or concern you may raise about our use of your information.
    4. The UK General Data Protection Regulation also gives you right to lodge a complaint the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
    5. If you would like this notice in another format (for example audio, large print, braille) please contact us (see 'How to contact us' above).

Last updated: 26 Jun 2022 19:34