We treat as confidential all of the personal information you give to us. By using the App or by registering as a user of any services provided by us, you agree to our use of your data as set out below. We will handle and process your personal data strictly in accordance with the data protection principles contained in the Data Protection Acts, 1988-2003 and the General Data Protection Regulations (GDPR).
[Our servers are located in a secure facility and any access to your personal data is strictly controlled and limited only to persons who are authorised and have appropriate security clearance to access the servers.]
[Saved payment card details are transmitted by us in an encrypted form to provide extra security for your online transactions. They are only shared with our payment partner and not with any other third parties and are only used to process your order, using our payment partner.]
If you have any queries relating to this policy or how your personal data is used by us please contact us by email at firstname.lastname@example.org or by post at Data Protection, Golden Discs, 36 Upper Fitzwilliam St, Dublin 2 .
COLLECTION AND USE OF INFORMATION
In the course of providing the Golden Discs loyalty program, we collect and use information for the purposes identified below.
- Registration: In order to participate in the Golden Discs loyalty program, you are required to create an account on our Website or App. To fully participate in it and earn and redeem stamps, you are also required to download, install and log-in to the Golden Discs App.
When you create an account, we collect your first and last name, email address, mobile phone number, and a password that you create. You can optionally provide your postal code. We use this information to create and administer your account and participation in the Golden Discs loyalty program.
We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
- Collecting Stamps: To earn stamps on your purchase, you are required to scan your receipt through the App and upload it to us. We collect information from the receipts, such as the store location, the date and time of the transaction, the ten-digit transaction number, the nine-digit operator ID, basic details of the product(s) purchased, and the total amount spent, in order to calculate the number of stamps you have earned, which you may then redeem in-store when your stamp card is full.
- Location Information: We may collect your location information by accessing your device’s GPS coordinates so that we can provide you with location-based services, such as sending you location-based push notification when you are within a close radius of a Store or showing you Stores nearby.
You can prevent us from collecting your location information or opt-out of location collection at any time by turning off your location services for the App in the settings of your mobile device.
- Push Notifications: If you provide your consent to receive push notifications, we may display push notifications on your mobile device such as welcome messages, product features and promotional offers. If you also have enabled location services for the App, we will send you real-time push notifications when you are within a tight radius of a Store.
If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.
- Subscribe to our Mailing List or Newsletter: When you create an account on the App, you may be provided with the option to sign-up to receive our email mailing list or newsletter (including Golden Discs offers and promotions). If you sign-up, we collect your name and email address. If you no longer wish to receive these communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our newsletter by contacting us at the contact information under “Contact Us” below or emailing us at email@example.com.
Third Party Platforms: - We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others and we may provide a anonymised or aggregated data, including yours, or other information to the platform provider for such purposes.
To opt-out of the use of your information for such purposes, you can contact us at the contact information under “Contact Us” below or email us at firstname.lastname@example.org.
- App Usage Information & Analytics: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identiﬁer, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience.
In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyse data in order to better understand our users.
SHARING OF PERSONAL INFORMATION
We do not sell, rent, or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.
- Service Providers/Third Party Processing: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as administering our surveys, hosting the Website, providing advertising services, and sending our marketing communications. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the EU, US, or other foreign jurisdictions. We require our service providers to comply on an ongoing basis with Irish and EU data protection requirements and transfers shall be made only to (a) safe countries (b) pursuant to the EU/US Privacy Shield or (c) pursuant to standard contractual clauses. By providing us with your personal information, you agree that we may transfer, store, and process your information outside the EEA..
- Legal and Compliance: We and our EU, US and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organisation for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable EU, U.S. or other law or legal process, which may include lawful access by EU, US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
- Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Golden Discs or as part of a corporate reorganisation or other change in corporate control.
SAFEGUARDS AND RETENTION
We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorised access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorised service providers who require access to fulfil their job requirements.
We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.
As indicated above, you can unsubscribe or opt-out of marketing communications any time by clicking the “unsubscribe” link for emails, newsletters or other communications included at the bottom of the email, newsletter, or communication.
Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below or by emailing at email@example.com.
If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.
You can opt-out of location tracking at any time by turning off your location services for the App in the settings of your mobile device.
YOUR OTHER RIGHTS
You have a number of rights under the GDPR and the Data Protection 2018.
- Right of Access – you have a right to request a copy of data we hold about you. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records
- Right of Rectification – You can request that we correct any errors in the information we hold about you.
- Right of Erasure/Deletion – You have a right to request we delete information we hold about you in certain circumstances. This is not an absolute right, but deleting data about you may result in you not being able to avail of services such as recording Golden Discs issued to you or using the App.
- Right to Object to Processing – You have a right to object to processing, particularly processing for the purposes of Direct Marketing. This is not an absolute right as we may have an over-riding requirement to continue processing your data. If we do opt you out of processing we might not be able to let you know about offers or promotions and it might have other implications depending on the specific processing you object to.
- Right to Restrict Processing – You have a right to ask us not to process your data for a period of time for a particular reason, for example if you have queried the accuracy of data we hold about you. Again, this is not an absolute right and it only applies in certain circumstances.
- Right to Data Portability – You have the right to ask us to transfer data we hold about you in a structured form and process using automated means to another company. This only applies if the basis of the processing is consent or contract.
- Right not to be subject to Automated Decision Making – You have a right not to be subject to automated decision making that has a legal or equivalent effect unless that processing is necessary for entering into or performing a contract, is required by law, or is conducted with your explicit consent. An example of such processing would include in-store credit checking.
- You have a right to compensation through the Courts in the event your data privacy rights under legislation are not upheld.
To avail of any of these rights, you can us contact in writing by email at [firstname.lastname@example.org] or by post at Data Protection, Golden Discs, 36 Upper Fitzwilliam St, Dublin 2. There is no fee for availing of these rights, but we reserve the right to charge a reasonable administrative fee for repeat requests for the same information.
To be able to use the App and to make full use of personalised features, your computer or mobile phone will need to accept cookies.
When you sign up for the App you will be asked to confirm whether or not you consent to us using cookies.
Our cookies don’t store sensitive information such as your name, address or payment details.
What are cookies?
Cookies are small text files sent from a website and stored in the user’s web browser while user is browsing a website .
When users visit the same website again, the browser sends cookies back to the website allowing the website to recognise the user and remember things like personalised details or preferences.
More information about cookies and details of how to manage or disable them can be found on aboutcookies.org and youronlinechoices.eu.
You can also download and use software that is available on the internet at no charge to you which will analyse the cookies used on any website that you visit and allow you to block one or more of those cookies.
Alternatively, you can contact us at email@example.com and we can assist you.
Which cookies does the App use?
When using the App a number of different types of cookies may be used. We have set out below a description of the cookies that are used by us or third parties that we work with.
Strictly necessary (Session) cookies
These cookies enable us or our service providers to provide services you have specifically asked for. Among other things they remember the position of any transaction that you are in the process of making.
These cookies are used to collect statistical information about visitors of the website and the pages they view.
These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used anonymously. We use these cookies to understand what content is popular which helps us to improve our website.
These cookies allow the website to remember choices you make and provide enhanced and more personal features.
Some examples of such features include remembering your preferences and settings.
Targeting and advertising cookies
These cookies are used to deliver advertising that is more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.
They are usually placed by advertising networks with our permission. They remember that you have visited a website; this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
Some examples of services that use these types of cookies include [Shopify – TBC].
Third Party Service Providers
Shopify (www.shopify.com) is one of our principal busines partner/service providers. They assist us with online purchases, marketing to customers and order processing.
Please also note that loyalty points will not be issued for any purchases using a Golden Discs gift voucher.