Custard customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

• Contact details
• What information we collect, use, and why
• Lawful bases and data protection rights
• Where we get personal information from
• How long we keep information
• Who we share information with
• App & website tracking
• Sharing information outside the UK
• How to complain

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery :

• Names and contact details
• Addresses
• Date of birth
• Purchase or account history
• Payment details (including card or bank information for transfers and direct debits)
• Website user information (including user journeys and cookie tracking)

We collect or use the following information for the operation of customer accounts :

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Purchase history
• Account information, including registration details
• Marketing preferences

We collect or use the following information for security and to prevent, detect, and investigate crimes, including fraud :

• Names and contact information
• Customer accounts and records
• Financial transaction information

We collect or use the following information for service updates or marketing purposes :

• Names and contact details
• Addresses
• Marketing preferences
• IP addresses
• Website and app user journey information

We collect or use the following personal information for dealing with queries, complaints or claims :

• Names and contact details
• Account information
• Purchase or service history
• Correspondence

We collect or use the following information to enhance user experience

• Gender
• Purchase or account history
• Website user (including user journeys and cookie tracking)
• IP addresses

We collect or use the following information for analytics and performance measurement

• Name
• Email address
• IP addresses
• Website user information (including user journeys and cookie tracking)

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here .
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here .
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here .
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here .
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here .
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here .
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here .

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please complete our privacy form here. To access the data we process about you, please visit our data portal here. Alternatively, you can contact our Data Protection Officer by email using the contact details at the end of this notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for the operation of customer accounts are:

• Legal obligation – we have to collect or use the information so we can comply with the law.
• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o In order to provide a seamless service, we create user accounts so our users can return and use our services without entering the same information again.

Our lawful bases for collecting or using personal information for security and to prevent, detect, and investigate crimes, including fraud are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o To ensure a fair service to our customers and to reduce our financial risk, we process user data for the purpose of detecting and preventing fraudulent activity.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We may send marketing communication to users who we believe would be interested in our services or similar third party services.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

o We process user data to respond fully to queries and complaints, and ensure our users are treated fairly.

Our lawful bases for collecting or using personal information to enhance user experience are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • To improve website functionality, optimise user journeys, and personalise your experience.

Our lawful bases for collecting or using personal information for analytics and performance measurement are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
• To analyse website traffic, user behaviour, and performance to optimise the website and improve your user experience.

Where we get personal information from

• Directly from you, for example from:
  • Contact forms: when you fill out a form to make enquiries, sign up for newsletters or request support
  • Account creation: when you register for an account and provide us with your details
  • Purchases or transactions: when you input personal information during the purchase process
  • Feedback and surveys: when you provide information through surveys, reviews or feedback forms
  • Support request: when you communicate with us via email or other support systems
• Automatically via our technology, for example from:
  • Cookies and tracking technologies: personal data such as IP address, browsing history and preferences gathered via cookies or analytics tools
  • Device information: data about your device (e.g. browser type, operating system, or screen resolution)
  • Usage data: behavioural information such as pages visited, time spent on the site, and actions performed
• From third parties, for example from:
  • Payment processors: information such as payment confirmation or billing details from our providers like Stripe and PayPal
  • Referral sources: data about users who were referred from other websites, affiliates or social media platforms
  • Advertising platforms: information from platforms like Google Ads or Facebook Ads about user interactions with ads.

How long we keep information

We only hold your data for as long as it is required for the purposes for which it was collected; for as long as it remains accurate and up-to-date; and most importantly, for as long as you are happy for us to do so. The length of time we keep your data will also depend on any legal obligations we may have.

Who we share information with

Data processors

Get Response

We use GetResponse to manage and send our email communications, including marketing emails and transactional messages. If you subscribe to our emails or use our services, your contact details may be processed by GetResponse for this purpose. For more information, see GetResponse’s Privacy Policy.

One Signal

We use OneSignal to send push notifications for both service updates and marketing purposes. OneSignal sets cookies and begins collecting certain technical data (such as IP address, device type, language, and session activity) as soon as it is loaded. To ensure compliance, OneSignal is only activated after you consent to marketing cookies via our cookie banner. Separately, you may also be asked by your browser to allow push notifications - this is a second opt-in managed by OneSignal which you can opt-out of at anytime. For more details, see OneSignal’s Privacy Policy.

TrueLayer

We use TrueLayer to securely process certain payments and verify account ownership. Your financial data is only shared with TrueLayer when you authorise a transaction, and it is processed in line with UK financial regulations. For more information, see TrueLayer’s Privacy Policy.

Revolut

We use Revolut to process payments. If you choose to pay via Revolut, your payment information is securely handled by them and not stored on our systems. For more information, see Revolut’s Privacy Policy.

Adjust

We use Adjust to track and analyse app usage and performance. This may include device identifiers and interaction data. Tracking only occurs with your consent, which can be managed via your device settings or our cookie banner. For more information, see Adjust’s Privacy Policy.

BriteVerify

We use BriteVerify to validate email addresses entered during sign-up or newsletter subscription. This helps reduce invalid or mistyped emails and improve communication accuracy. For more information, see BriteVerify’s Privacy Policy.

HLR Lookup

We use HLR Lookup to check the validity and status of mobile numbers. This helps us ensure accurate messaging and reduce failed communications. For more information, see HLR Lookup’s Privacy Policy.

LEM Verify

We use LEM Verify to confirm user identity and prevent fraud during onboarding or verification steps. This may involve checking ID documents and facial recognition, where required. For more information, see LEM Verify’s Privacy Policy.

Trustpilot

We use Trustpilot to collect and display reviews from our customers. If you submit a review, your name, email address, and order reference may be shared with Trustpilot to authenticate your feedback. For more information, see Trustpilot’s Privacy Policy.

PayPal

We use PayPal as one of our payment processors. If you choose to pay using PayPal, your payment data is securely processed by them and not retained by us. For more information, see PayPal’s Privacy Policy

Hotjar

We use Hotjar on our website(s) and/or app(s) in order to better understand how our users interact with our services and to optimise our services and user experience. Hotjar allows us to visualise user interactions that helps us better understand our users’ experience to improve our services by identifying issues and friction points. To provide these services, Hotjar uses first-party cookies and other technologies to collect personal data on our users’ behaviour, and their devices on our behalf. This may includes personal data like online identifiers (e.g. device's IP address, user ID), identification data (e.g. name, email address, only if we explicitly collect it), technical data (e.g. device type and screen size, browser information), geographic location (country only), behavioural data (interactions with our website/app such as clicks, taps, scrolls), and any additional personal data that may explicitly submit through Hotjar such as name, email address and gender. Hotjar may reuse this personal data to develop and improve tools and services for us and our users. For further details, please visit Hotjar’s Trust Portal and Privacy Policy.

Anura

We use Anura to detect and prevent advertising fraud by identifying non-human or invalid traffic. This helps us protect our marketing spend and ensure data integrity. For more information, see Anura’s Privacy Policy.

CAKE

We use CAKE to manage and track performance marketing campaigns, including attribution and analytics. CAKE may process device and browser data when you interact with our marketing links. For more information, see CAKE’s Privacy Policy.

Freshdesk

We use Freshdesk to manage customer support queries and communication. If you contact us for support, your message and contact details may be processed by Freshdesk. For more information, see Freshdesk’s Privacy Policy.

Stripe

We use Stripe to manage and process online payments. Your payment details are shared directly with Stripe and are processed in accordance with their security and privacy standards. For more information, see Stripe’s Privacy Policy.

Tillo

We use Tillo to supply digital gift cards. If you choose to receive a gift card, your email address or other necessary information may be shared with Tillo for fulfilment purposes only. For more information, see Tillo’s Privacy Policy.

Marketing Service Providers

Advertising - we may share your data with Meta Platforms Inc. (Facebook and Instagram), Google LLC, Snap Inc (Snapchat) and TikTok Information Technologies UK Limited to perform ad-measurement services and provide offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.

In sharing your data with Marketing Services Providers, we rely on a lawful ground called ‘legitimate interest’, as our business depends on our ability to partner with third parties who process personal data for marketing-related reasons.

You can opt-out via the communication preferences in your account. You can also manage how we share your data with Facebook and Instagram via Activity Off-Meta Technologies which can be found in the Settings menu on Facebook, Instagram and Messenger. You can further manage how we share your data with TikTok via the Ads page in your TikTok app’s Settings and Privacy.

For more information, please contact our Data Protection Officer by email: dpo@submissiontechnology.co.uk

Use of Data for Audience Matching

We may securely share limited personal information (such as your email address, first name, and last name) with trusted advertising platforms, including Google Ads, to help deliver more relevant ads to you and others with similar interests. This process is known as Customer Match or audience matching.

Your information is hashed and encrypted before being shared, and is only used to match against existing platform users. This does not allow the advertising platform to identify you personally or to access your full data.

We rely on your consent and/or our legitimate interest in promoting our services in a privacy-conscious and relevant way. You can opt out of personalised advertising at any time by adjusting your cookie preferences or visiting YourAdChoices or Google’s Ads Settings.

Others we share personal information with

• Financial or fraud investigation authorities
• Suppliers and service providers

App & website tracking

How We Use Tracking Technologies

We use tracking technologies to track conversions, to issue you your earned cashback, to improve your experience, to provide relevant offers to you, to measure interactions and to optimise our advertising platform. Our Privacy Notice should be read in conjunction with our Cookie Policy. This includes:

• Website Tracking: When you visit joincustard.co.uk, we may collect data using cookies and similar technologies, as outlined in our Cookie Policy.
• App Tracking: When you use our iOS or Android app, we may request your permission to use the Identifier for Advertisers (IDFA) and Android equivalent. Any third party with whom our app shares user data will provide the same or equal protection of user data to this and our app’s privacy notice.

Your Choices & Controls

When you download our app, we will ask you for your consent to track. When you visit our website for the first time, we will ask you for your consent to track. You can manage tracking in your phone settings for the app. You can manage tracking on the web via our cookie management tool on our website - see the CookieBot icon in the bottom lefthand corner of your desktop or mobile device.

• If you accept tracking in the app, we will collect and share your IDFA with third parties (such as advertisers) for conversions, attribution and targeted advertising.
• If you decline tracking in the app, we will not share your IDFA with third parties.

Cross-Platform Tracking

• If you sign up and consent to tracking on our website, we may continue tracking your interactions when using our website, even if you later decline app tracking.
• If you decline tracking in the app, we will not attribute app interactions to advertising, but web-based tracking may still apply if previously consented to.
• Some tracking is necessary to provide you with the functionality of our service. When you create an account with us, you will be asked to accept our Terms and Conditions, and Privacy Notice which detail when and how we use your data.

Sharing information outside the UK

Organisation Name	Category of Recipient	Country	Safeguard
GetResponse	Email Service Provider	Poland	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Anura	Ad Fraud Prevention Provider	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)
CAKE	Marketing Attribution Platform	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Hotjar	Analytics and User Behaviour Tracking	Malta / EU	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Freshdesk	Customer Support Software	India / Global	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Stripe	Payment Processor	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)
PayPal	Payment Processor	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Trustpilot	Review Platform	Denmark / EU	UK Addendum to the EU Standard Contractual Clauses (SCCs)
Adjust	App Analytics and Attribution	Germany / Global	UK Addendum to the EU Standard Contractual Clauses (SCCs)
BriteVerify	Email Address Validation	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)
LEM Verify	Identity Verification Service	UK / Potential Global	UK Addendum to the EU SCCs (if applicable)
Stripe	Payment Processor	United States	UK Addendum to the EU Standard Contractual Clauses (SCCs)

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Contact details

Email

dpo@submissiontechnology.co.uk

Last updated

2 June 2025