For the purpose of the Data Protection Act 1998, the Data Controller is SP Social Ltd.
Effective Date: May 25, 2018
1. WHAT INFORMATION DO WE COLLECT?
There are several ways we may obtain personal information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. Personal information is data that identifies you personally whether directly (i.e. your name) or indirectly (i.e. information about your online use).
A. Information You Provide To US
When you use the SPS Services, we may ask you to provide certain personal information. For example, we may ask for information when you register to create an account, update your information, sign up for a membership or subscription, use certain features, access, upload or download content, purchase Products or services, enter into sweepstakes or other promotions, register or participate in a competition, fill out a survey, request customer support, or otherwise communicate with us.
We (or our service providers or business partners) may collect information that relates to you, including personal information, such as your name, e-mail address, telephone or mobile number, mailing address, date of birth, gender, and demographic information. You are not required to provide SPS with your personal information, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
Information You Provide When You Participate in an Online Survey or Other Research. We may also collect information you provide us in connection with participating in an online survey or as a research panel participant. This may include, but may not be limited to, information about your shopping habits, lifestyle preferences, interests and hobbies, health, physical or behavioral characteristics, or other demographic information, as well as photos, videos, and other user-generated content.
Information You Provide When You Make a Purchase. If you make a purchase from us, you will be required to provide a credit/debit card number and related financial information (such as CVV, expiration date, and billing address), or other payment information (such as via PayPal or Apple Pay), depending on the form of payment you choose.
Information You Provide Through Social Media. You may also be given the option to link to your Facebook or other social media accounts through the SPS Services. When you do, we may automatically receive certain information from you based upon your privacy settings on those sites. This may include, but may not be limited to, name, user name, demographic information, updated address or contact information, location, interests, and publicly-observed data, such as from social media and online activity.
B. Information Collected Automatically
Whenever you visit or interact with the SPS Services, SPS, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about your online activity.
Device. We may automatically collect your IP address or other unique identifier for the computer, mobile device, tablet or other device you use to access the SPS Services, including the hardware model and mobile network information. The data may be used to help diagnose problems with our servers, analyse trends, track users’ web page, email and mobile application movements/activities (such as for fraud prevention purposes and to support our marketing efforts), help identify or gather broad demographic information for aggregate use, and retarget online and mobile advertisements to you across computers or devices you may use.
Location. We collect general information about where traffic and purchases on our site are coming from around the world. This is used at an aggregate level (that does not identify individual users) to create reports to better understand our engagement with users.
Third Party Service Providers. We may use third party service providers to support the SPS Services. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store information on our behalf.
Third Party Analytic Technologies. We may use third parties’ analytics and tracking tools, such as Google Analytics, Adobe Marketing Cloud, Facebook Custom Audience and others, to help us track, segment and analyze usage of the SPS Services, and to help us or those third parties serve more targeted advertising to you on the SPS Services and across the Internet.
To learn more about your advertising choices relating to the collection and use of your information, please see the Your Rights section below.
C. Information Received from Other Third-Party Sources
SPS may receive your personal information as follows:
We may obtain information about you from other trusted third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, Public databases or data aggregators (that may include your demographic information, media consumption, previous purchases, shopping habits, loyalty program information or lifestyle preferences);
SPS partners and service providers (including, for example, business partners, analytics vendors, advertising networks and search information providers).
We may use this information to help us maintain the accuracy of the information we collect, personalise your experience with the SPS Services, target our communications so that we can inform you of Products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
D. Combination of Information
3. HOW DO WE USE THE INFORMATION WE COLLECT?
We will have a lawful basis for processing your data if:
- we need to process your information in order to provide you with the Products or service you have requested or to enter into a contract;
- you have consented to such processing – g., when you sign up to receive promotional emails or other electronic communications from us;
- we have a legitimate interest for processing your data – g., for fraud prevention and abuse tracking; direct marketing; network and information systems security; data analytics; website content delivery; enhancing modifying or improving our services; identifying usage trends; determining the effectiveness of promotional campaigns; and personalisation of the service using data to make it easier and faster for you to place orders; and/or we are legally obliged to process it.
- We may use your personal information for Customer Service and Transactional Purposes, such as to:
- respond to your questions or requests and provide customer service;
- manage your account and registration;
- troubleshoot issues, bugs or defects related to your account or activities;
- provide you with access to certain features of the SPS Services;
- validate, confirm, verify, deliver, and track your order (including to arrange for shipping, handle returns and refunds, and contact you about your orders, including by telephone), and send you related information, coupons, Products or samples;
- verify your identity or communicate with you about your activities with respect to the SPS Services;
- use your credit, debit or payment card or other financial information only to process payments and prevent fraud;
- develop new Products or services and to enhance current Products and services;
- protect the security or integrity of the SPS Services and our business., such as by protecting against and preventing fraud, unauthorised transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorised users; and
- for other purposes as disclosed at the time you provide your personal information or otherwise with your consent.
- We may use your personal information for Advertising Customisation and Analytics Purposes, such as to:
- provide you with customised content, advertisements, offers and promotions offered by SPS or on behalf of our partners and affiliates;
- communicate with you, either directly or through one of our partners (e.g., through Facebook Custom Audience, Google Customer Match, Twitter Match, etc.) for SPS marketing and promotional purposes via emails, notifications, or other messages, consistent with any consents you have given to us.
- You can refuse to provide your consent to our collection of non-essential cookies;
- You can disable SPS or third-party cookies by use of your browser settings; or
- You can use opt-out tools provided by the Digital Advertising Alliance (DAA), European Interactive Digital Advertising Alliance (EDAA), or National Advertising Initiative (NAI) for participating companies.
- Our performance, functionality and targeting/advertising Cookies are not strictly necessary for the SPS website to work but will provide you with a better browsing experience. You can delete or block these Cookies, but if you do this, you may have to manually adjust some preferences every time you visit the SPS site and some features of the site may not work as intended. For example, you may not be able to visit certain areas of the SPS site or you may not receive personalized information when you visit our site.
- Control via your browser settings
- Most internet browsers are initially set up to automatically accept Cookies. If you do not want our website to store Cookies on your computer or device, you can change or adjust your browser or device settings to block Cookies or to alert you when Cookies are being sent to your device.
- If you use different devices to view and access the SPS website (e.g. your computer, smartphone, tablet, etc.) you will need to ensure that each browser on each device is adjusted to suit your Cookie preferences.
- The procedures for changing your settings and cookies differ from browser to browser. If necessary, use the help function on your browser or click on one of the links below to go directly to the user manual for your browser.
- Disable Cookies in Internet Explorer >> Click here
- Disable Cookies in Chrome >> Click here
- Disable Cookies in Safari >> Click here
- Disable Cookies in FireFox >> Click here
- Disable Cookies in Safari IOS >> Click here
- Disable Cookies in Google Android >> Click here
3. WHO MIGHT WE SHARE YOUR INFORMATION WITH?
The information collected or generated through your use of the SPS Services may be shared by you or by us as described below.
A. Sharing of Information by You
The SPS Services offer many ways to find, enjoy, and share content.
Your activity in connection with the SPS Services, such as filling out surveys, reviewing and rating Products, inquiring about or purchasing Products, participation in online communities, “liking” or “sharing” SPS content to your social media accounts or pages or otherwise interacting with the SPS Services, may be visible to other users of the SPS Services and in some cases, publicly available.
B. Sharing of Information by Us
We may share your personal information with:
Our Affiliates. We may share your personal information with our subsidiaries and affiliated companies for internal reasons, primarily for business and operational purposes.
Third Party Service Providers. We may share your personal information with third-party service providers that provide business, professional or technical support functions on our behalf. This includes, but may not be limited to, service providers that host or operate the SPS Services; process payment; analyse data; provide customer service; postal or delivery services, and sponsors or other third parties that participate in or administer any promotions. We are not responsible for these sites or their content, products, services or privacy policies or practices. These other web sites may send their own cookies to your device and may independently collect data or solicit personal information and may or may not have their own published privacy policies. We may also transfer or disclose your personal information to another data controller to be used for similar purposes, at that data controller’s discretion and you hereby consent to such transfer or disclosure.
Other Third Parties. Your personal information may also be shared with our sponsors, partners, advertisers, advertising networks, advertising servers and analytics companies or other third parties in connection with marketing, promotional, and other offers, as well as product information. Your information may also be shared with third parties we identify at the time you provide your personal information or otherwise with your consent. You have the option to opt-in to receive direct marketing from these selected third parties. With your consent, we will also share your information with members of our corporate family who will use your personal information to send you marketing communications. You can change your mind and opt-out at any time as detailed in Your Rights below.
Business Transfers. In the event that another entity acquires us or all or substantially all of our assets, or assets related to the SPS Services, your information may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. Finally, information described in this paragraph may also be disclosed for due diligence purposes in connection with any proposed transaction of the sorts described in this paragraph.
Legal obligations. In limited circumstances, we may transfer and disclose your information to law enforcement and government authorities to comply with our legal obligation.
4. HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
We keep your personal information for as long as we need it for the purpose it is being processed for; afterwards, we may take steps to securely delete or otherwise anonymize or aggregate your personal information.
We will keep your personal information for as long as we need it for the purpose it is being processed for. For example, we will retain your information for as long as your account is active or as needed to provide you services you request; and after that, we will keep the personal information for a period of time which enables us to handle or respond to any complaints, queries or concerns relating to your account. Your information may also be retained so that we can continue to improve your experience with us. After this we may take steps to securely delete your personal information or otherwise anonymize or aggregate such information, when there is no longer a legal, business, or consumer need for it to be retained.
5. WHAT ARE YOUR RIGHTS?
By law, you have a number of rights when it comes to your personal data. If you wish to exercise these rights with regards to your personal information that we hold, please send an email to firstname.lastname@example.org. Please include the statement “Data Subject Request” in the subject line.
6. WHAT ABOUT CHILDREN’S PRIVACY?
Our Services are not directed to children, and we do not knowingly collect information from children under 16.
We do not direct the SPS Services to, nor do we knowingly collect any personal information from, children under the age of sixteen. If SPS learns that a minor has provided personal information through the SPS Services, we will use reasonable efforts to remove such information from our files.
7. HOW DO WE SECURE YOUR INFORMATION?
While no data collected on the internet is 100% secure, we use reasonable security measures to help protect your personal information.
8. DO WE TRANSFER DATA INTERNATIONALLY?
SPS is a global business and it, or its service providers, may process, transfer, and store information about our users on servers located in a number of countries outside the European Economic Area (EEA), including to the United States. Since we are committed to protecting your information, we take reasonable steps to ensure that there are appropriate safeguards in place when we transfer that data.
In some locations where your data is stored by SPS or its service providers, the data protection laws may be less stringent than in the UK or EEA. To ensure that your data is adequately protected, we only transfer your data subject to adequate and appropriate safeguards being in place, such as through the use of approved standard EU Model Clauses or to companies who are Privacy Shield certified. We also make sure that any such transfers are conducted in accordance with applicable data protection laws.
To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the ‘Contact Us’ section below.
9. HOW DO WE COMMUNICATE CHANGES TO OUR PRIVACY POLICIES?
If we make changes, we’ll post it on this page. If the changes are material, we’ll provide appropriate notice to you.
10. HOW CAN I CONTACT SPS IF I HAVE QUESTIONS ABOUT THIS POLICY?
Effective Date: May 25, 2018
This Cookie Notice applies to information collected and used by Sweet P Social (“SPS,” “we,” “our” or “us”) when customers access the SPS website. Like many companies, we use technology on our website to collect information that helps us enhance your experience and our products and services. The Cookies and various other technologies that we use at SPS allow our website to work and help us to understand what information and advertising is most useful to visitors. You are free to limit certain tracking or to decline Cookies in relation to Cookies which are not necessary, but by doing so, you may not be able to use certain features on our website or take full advantage of all of our offerings.
This Cookie Notice summarises the different types of cookies we use on our website, together with their respective purpose and provides you with the ability to manage these cookies. Please take a moment to familiarise yourself with our cookie practices and let us know if you have any questions by sending us an email at email@example.com
1. What are Cookies?
Cookies, pixel tags and similar technologies (collectively 'Cookies') are files containing small amounts of information which are stored by your browser (for example, Internet Explorer or Safari) on any Internet-enabled device – such as your computer, smart phone, or tablet – when you visit a website.
Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different and useful jobs, such as remembering your actions and preferences (such as login, language, font size and other display preferences), distinguishing you from other users of the SPS site, generally improving your online experience, and helping us to offer you the best product and services.
3. How can you control or delete Cookies?
We provide you with several ways to manage cookies:
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
Additional Mechanisms for Exercising Choice
We, or other parties we do business with, may place or recognize unique cookies or other technologies placed on your browser when you visit the SPS website to collect information about your use of the website and your other online activities over time and across different websites and apps, and may use that information to serve interest-based advertisements to you as you browse the Internet.
To learn more about your choices for receiving interest-based advertising or to opt-out, please review the information below:
DAA: To opt-out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit: http://www.aboutads.info/choices
EDAA: To opt-out from the use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit: http://www.youronlinechoices.eu/.
NAI: To opt-out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) participating companies, please visit: http://www.networkadvertising.org/choices/.
Please note that even if you opt-out, you may still receive advertisements from SPS that are not customized based on Cookies.
4. What types of Cookies do we use?
The cookies used on our website may be generally categorised as follows:
Necessary/Essential Cookies. These cookies are necessary to make our website function and do not identify you as an individual.
Performance Cookies. These cookies help us understand how you interact with the website and do not identify you as an individual.
Functionality Cookies. The information these cookies collect may include personal data that you have disclosed.
Targeting or Advertising Cookies. Most types of these cookies track consumers via their Device ID or IP address therefore they may collect personal data.
Third-Party Cookies. Based on the type of cookies used by the relevant third-party, the information these cookies collect may include personal data.
These Cookies are essential to make our website work correctly, they enable you to move around our website and use our features. Without these, you would not be able to navigate between pages or use certain vital features of our website. For example we use a necessary Cookie to record where you have added an item into your basket so you are able to view and pay for this item when you checkout. These Cookies are necessary for the provision of the Service to you and we do not require your consent for use of these particular Cookies. If you do not want us to collect such information, you must cease using our website immediately. By continuing to use our website, you accept that these necessary Cookies are vital for provision of such services and will be placed on your browser as normal.
Do these cookies collect personal data/identify me? These cookies do not identify you as an individual. If your browser does not accept these cookies, it may affect the performance of the website, or parts thereof.
These Cookies help us understand how you interact with the SPS website by providing information about the areas visited, the time spent on the website, and any issues encountered, such as error messages. This helps us improve the performance of our website. They also may be used to keep track of what featured products or videos have been viewed to avoid repetition, and to enable you to engage with social tools, such as blogs, chatrooms and forums.
Do these cookies collect personal data/identify me? These cookies do not identify you as an individual. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
These Cookies allow the SPS website to remember if you have previously visited our site or the choices you make (such as your user name, language, region or preferences) to provide a more personalised online experience. These cookies may also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. Similarly, they may be used to keep track of what featured products or videos have been viewed to avoid repetition, and to enable you to engage with social tools, such as blogs, chatrooms and forums.
Do these cookies collect personal data/identify me? The information these cookies collect may include personal data that you have disclosed. If you do not accept these cookies, it may affect the performance and functionality of the website and may restrict access to content on the website.
Targeting or Advertising Cookies
These Cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They help us measure the effectiveness of advertising campaigns on our websites and may also result in your seeing advertisements for some of our products you may be interested in when visiting other websites or apps. We may use these Cookies to remember websites you have visited and we may share this information with third parties, including advertisers and our agencies.
Do these cookies collect personal data/identify me? Most types of these cookies track consumers via their computer or device ID or IP address therefore they may collect personal data.
Third Party Cookies
We use a number of partners that may also set cookies on your device on our behalf when you visit our websites to allow them to deliver tailored SPS advertising within their domains, for example Facebook and Google DoubleClick. We endeavour to identify these cookies before they are used so that you can decide whether you wish to accept them or not. We also use a number of partners to provide digital experiences and functionalities on our websites. For example, while browsing the SPS website, you may be served cookies from third-parties who provide some of its features on our websites (e.g., a YouTube video), although you have withdrawn or declined your consent to our cookies. This happens because you have directly given your consent to the use of their cookies. In such cases, you should directly withdraw your consent on the relevant third-party website.
Do these cookies collect personal data/identify me? Based on the type of cookies used by the relevant third-party, the information these cookies collect may include personal data.
Duration of the Cookies We Use
In terms of duration, we may use two different types of cookies on our websites:
Session Cookies. These Cookies are temporary cookies that remain on your computer or device until you leave our websites. They allow websites to link your actions during a browser session. We may use these for a variety of purposes such as remembering what you clicked on, on the previous page visited. These session Cookies expire after a browser session so would not be stored longer term. For this reason, session Cookies are generally considered less privacy intrusive than persistent Cookies; or
Persistent Cookies. These cookies remain on your computer or device for much longer or until you manually delete them (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie, as well as your browser settings, as stated below). Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.
5. Any questions?