Custard customer privacy notice
Registered name: Submission Technology Ltd
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
- Sharing information outside the UK
- How to complain
Contact details
info@joincustard.co.uk
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 and guarantees :
- 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 to prevent, detect, investigate or prosecute crimes :
- 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
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 contact us using the contact details at the top of this privacy 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 and guarantees are:
- Legal obligation – we have to collect or use the information so we can comply with the law.
- 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 to prevent, detect, investigate or prosecute crimes 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.
Where we get personal information from
- Directly from you
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.
Data |
Retention Period |
|
|
12 months since your most recent activity in your account |
|
|
6 years on our suppression list if you ask us not to contact you again |
|
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6 years if you cashed out or made a purchase |
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Who we share information with
Data processors
Get Response
This data processor does the following activities for us: Manage and send our emails, for marketing and transactional purposes
One Signal
This data processor does the following activities for us: Manage and send our push notifications, for marketing and transactional purposes
Tillo
This data processor does the following activities for us: Gift card supplier
TrueLayer
This data processor does the following activities for us: Payment provider
Stripe
This data processor does the following activities for us: Payment provider
Adjust
This data processor does the following activities for us: App tracking platform
BriteVerify
This data processor does the following activities for us: Email address validation
LEM Verify
This data processor does the following activities for us: Identity checker to detect and prevent fraud
TrustPilot
This data processor does the following activities for us: Review platform
PayPal
This data processor does the following activities for us: Payment provider
Lloyds Banking Group
This data processor does the following activities for us: Payment provider via bacs
ToroX
This data processor does the following activities for us: Marketing offer wall
Others we share personal information with
- Financial or fraud investigation authorities
- Suppliers and service providers
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name:Get Response
Category of recipient:Email Service Provider
Country the personal information is sent to:Poland
How the transfer complies with UK data protection law: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:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Last updated
10 September 2024