Bufflunch Privacy & Cookies Policy
Effective date: 21th November 2019
1. General Information
At Bufflunch we take your privacy seriously and are committed to protecting your information online.
This policy explains how Bufflunch Ltd collect, control, process and use information about you (i.e “personal data”)
This policy applies to both website www.bufflunch.com and applications (User & Merchant) and for the purposes of this document shall be referred to as Bufflunch Platforms.
When we state “Bufflunch”, “Us”, “Our” or “We”, we mean Bufflunch Ltd. Bufflunch provides platforms for restaurants and food outlets and sellers (collectively “Merchants”) where they can offer deals and vouchers and other offerings.
Bufflunch Ltd is registered as data controller under the Data Protection Act 1998 (the “Act”).
By using Bufflunch Platforms you consent to the collection and use of information in accordance with this policy.
2. Policy Change
3. Data we collect
We will collect the following personal data when you interact with the Site:
- Authentication and identification information (e.g. user name, email address, and password). This information is necessary to set up and log you into your account. If you don’t provide it, we may not be able to provide our services to you;
- Basic personal details (e.g. user name);
- Contact details (e.g. your postal address, telephone number, and email address). We may need some of this information to deliver products to you, such as your postal address, and won’t be able to carry out these services if you don’t provide it;
- Payment details (e.g. your credit card details or payment tokens from third party payment providers like PayPal). We use these to process your order, and won’t be able to take payment from you or give refunds if you don’t provide it; and
- Information about your contacts with Bufflunch (e.g. call recordings, instant messages on our site, and user generated content).
Some information we collect is necessary for us to provide our services or meet our legal obligations. We will make this clear when we collect that information from you.
We will also automatically collect personal data when you interact with the Site through your computer, mobile device, or other device. This personal data includes the following:
- Analytics data (e.g. information about app downloads, app and web page histories), which may include data collected from cookies and other types of device identifiers;
- Profile inputs (e.g. page and deal views on the site, click information and information about the website you clicked to our Site from). This may include data about your location. With respect to geolocation information collected from your mobile device, we will only collect this where you have provided consent; and
- Device details (e.g. MAC address, IP address, bluetooth data and advertising identifiers).
We also receive personal data and other online and offline information from third parties with whom we conduct business, such as merchants, co-marketers, distributors, resellers, and other companies or organizations with whom we enter into agreements to support our business and operations, including advertising partners and third party data providers that provide us with supplemental or additional information about our customers (collectively “Business Partners”).
The personal data we receive from Business Partners includes basic personal details, contact details, device details, profile inputs, as well as:
- Demographic information, (e.g. details about age brackets);
- Location data (e.g. information about postal or ZIP code, or location services on your mobile); and
- Purchase information from third party sites (e.g. information about purchases on other sites).
We will only receive data from our Business Partners where they are legally permitted to share such data, and we will only process that data for the purposes described below. We use the data provided to better understand your preferences, deals that are relevant to you, and how our merchants are performing. By combining the data we collect directly from you with that received from third parties, we are able to provide you with a better, and more personalized, Bufflunch experience.
We will collect the personal data described above at various stages in your relationship with us when you:
- Register, subscribe, authorise the transfer of, or create an account with us;
- Open or respond to emails or messages from us;
- Provide information to enrol or participate in programs provided on behalf of, or together with Sellers and Business Partners, with your consent or as necessary to provide services you have requested;
- Visit any page online that displays our ads or content;
- Purchase products or services on or through the Site from Sellers;
- Connect, log-in, or link to the Site using social networking tools; and
- Post comments to the online communities sections of the Site.
We also create profiles about you based on the personal data you provide to us or that is collected about you, as described above and including personal data that we receive from Business Partners. We do this to market offers to you we think you would be interested in buying. The contents of that profile include:
- Account details. For example, we create a permanent URL to your account page which may include your user name. We also generate tokens to remember your subscription and purchase histories, and any Buffcoins you may have obtained;
- Marketing segment information. For example, if you purchase products or services related to clothing on the Buffstore, we may infer that you are interested in these types of products, or if you purchase Italian deals or vouchers we may infer that you are interested in Italian food;
- Audience information. We create audiences based on parameters such as gender, age, and location (e.g. females aged 30-40 in your city), and if your personal data matches those audiences, you’ll be assigned to it. This is to help you receive relevant offers; and
- Activity information. Based on your interactions with communications, we’ll generate personal data about how many communications you like to receive, so that we don’t send you more than are useful to you.
4. Your choices
You can manage the types of personal data you provide to us and can limit how we communicate with you. At the same time, we think that the more you tell us about yourself and what you like, the more relevant and valuable your experience with our Site and services will be.
You can manage your email, push notification, location information and subscription notification preferences by logging into your account through the Site or by adjusting the settings in our mobile application:
- Push notifications and location information. Your device and the Bufflunch mobile app provide you with options to control push notifications and how and when we collect your geolocation. You can disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the Bufflunch application in Apple’s iOS and Android privacy settings, or by disabling “Location” services for your device;
- Subscriptions. You can also manage your subscriptions by following subscription management instructions contained in any commercial emails that we send you. You may choose to subscribe to some types of messages, and may choose not to subscribe to, or to unsubscribe from, others. You may update your subscription preferences at any time. Even if you decide not to subscribe to, or to unsubscribe, from promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases from Sellers. For example, even if you have unsubscribed from our promotional email messages or push notifications, we will still send you confirmations regarding feature changes within Bufflunch Platforms;
- Cookies. You can manage how your browser handles cookies. You may also manage how your mobile device and mobile browser share information on and about your devices with us, as well as how your mobile browser handles cookies. You can block cookies by activating a setting on your browser allowing you to refuse the setting of cookies. You can also delete cookies through your browser settings. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website will not function fully.
- Objecting to uses of data. In certain circumstances, you have the right to object to the use of your personal data. If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions within Bufflunch platforms without personal data. In particular, you can object to our use of personal data where we use such data to meet our own interests in running our business (as described under ‘How We Use Information’ below and including use of your data for marketing purposes and management of our business needs). If you object to our use of your data, we will assess the objection and cease processing that data upon confirmation of a valid request. For more information, see ‘Your Rights’ below;
5. Your rights
You can access, update, rectify, and delete your personal data which makes up some of your profile by logging into your account or contacting us here. Keeping your personal data current helps ensure that we can respect your preferences and offer you the goods and services that are most relevant to you.
In accordance with applicable law, you may
- request access to any personal data we hold about you;
We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of other (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason.
- request that it be updated, rectified, deleted or blocked;
- request that we delete personal data we hold about you;
- request that we restrict our processing of your personal data;
- request that we provide you or a third party with a copy of certain personal data about you (that is referred to as the right of “data portability”). You can also object to any of our uses of your personal data described in this policy, including our marketing activities. You may also revoke your consent to the processing of your personal data, to the extent consent was required and provided by you.
- lodge a complaint regarding our use of your data;
Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the UK Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.ico.org.uk.
You can exercise your rights by sending us an email at email@example.com.
6. How we use information
We control and process the personal data you provide to us, which we collect from other sources, and which we generate to:
- Operate, maintain, and improve the Site by analysing how you and our other customers use and interact with it. This is to meet our legitimate business interests in providing the Site and ensuring that it provides the best experience for our customers;
- Carry-out marketing, which may involve:
- Establishing and analysing individual and group profiles and customer behaviour, in order to determine your or others interest in certain types of offers, products, and services. We do this by analysing your interactions with Bufflunch Platforms and your other personal data (including personal data received from Business Partners) to determine what your interests are, and what sorts of products and services people with similar interests also buy, which helps us understand what products and services you may be interested in viewing. This is to meet our legitimate interests in understanding the types of products and services our customers are interested in, and to provide the most relevant products to you and our other customers;
- Showing relevant offers and advertising. We will use the profiles described above to create advertising for our products that will be displayed on relevant third-party sites. We do this to meet our legitimate interests in showing you products which may be relevant to you, and you can opt out of seeing these types of ads as described in our Cookies Policy;
- Sending you relevant direct marketing messages and other communications via email or push notifications on mobile devices, including, with your consent, using your location data to notify you of tailored location-based deals. We will either send these messages on the basis that you have consented to receiving them or, where permitted by applicable law, to meet our legitimate interests in showing you which of our products and services are relevant to you; and
- Analysing advertising effectiveness, which may involve analysing the advertising campaigns our customers choose to interact with most often. This is to meet our legitimate interests in understanding which types of advertising campaigns are more or less effective than others.
- Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, and requested information, including on behalf of Business Partners, EU Affiliates, or other Sellers. This is to meet our legitimate interests in managing our relationship with you effectively;
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events, in order to meet our contractual commitments to you set out in the terms and conditions of those promotional events;
- Comply with our legal obligations, resolve disputes, and enforce our agreements. We do this where necessary to comply with legal obligations to which we are subject, or to meet our legitimate interests in enforcing our legal rights and resolving disputes or verifying payments and preventing fraud.
7. Disclosure of personal data
We share your personal data as follows:
- with your consent;
- in order to enforce any terms and conditions or agreements for our services that may apply;
- with EU Affiliates and other Bufflunch entities within and outside of the European Economic Area, who will process your personal data only in accordance with our instructions and for the purposes set out in this Privacy Statement;
- with unaffiliated third-party Sellers and Business Partners in order to describe our services, including providing aggregate statistics regarding visitors to Merchant restaurants, cafes and bars. These statistics will not include any personally identifiable information.
- with unaffiliated third-party Sellers and Business Partners, so they can sell, deliver, and provide the products or services purchased by you. We share personal data with unaffiliated third-party Sellers and Business Partners in order to meet our contractual obligations to you, and they are not permitted to use your personal data in any way other than for selling, delivering, and/or providing the products or services purchased by you;
- with third parties that provide tools and services to help us better understand your deal preferences, so that we can show you advertisements for Bufflunch vouchers, deals, or services on third party websites which are more suited to your interests and tastes. Those third parties may also use your personal data to match you with their existing customer base. You can stop our use of these tools in the ways described in our Cookies Policy;
- to report or collect on debts owed to Sellers or other Business Partners;
- as necessary to perform contractual obligations towards you with Sellers or Business Partners to the extent you have purchased or redeemed a Bufflunch voucher, deal, or services offered by them or participated in an offer, rewards, contest or other activity or program sponsored or offered through us or the Sellers on behalf of a Business Partner;
- to a subsequent owner, co-owner, or operator of one or more of the Sites or any portion or operation related to part of one or more of the Sites;
- in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process;
- to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions, where this is necessary to comply with these legal obligations;
- to combat fraud or criminal activity, and to protect our rights or those of our EU Affiliates, Sellers, or Business Partners, and users, or as part of legal proceedings affecting us and/or our EU Affiliates, as it is in our legitimate interests to prevent fraud and protect these rights; or
- in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts, to the extent this is necessary to comply with such legal obligations.
We encourage our unaffiliated third-party Sellers and Business Partners to adopt and post privacy policies. However, while we share personal data with Sellers and Business Partners only for the above-mentioned purposes, their subsequent processing and use of personal data obtained through us and our European Affiliates is governed by their own privacy policies and practices and is not under our control (except for the use and processing by Sellers and Business Partners providing services to us, as described above). Where possible, we contractually restrict how our Sellers and Business Partners, including merchants, use your personal data and aim to ensure they do not use it for any purposes which are incompatible with those set out in this privacy statement.
In a number of the cases set out above, we will transfer your personal data to a country located outside the European Economic Area that may not be considered as providing the same level of protection for personal data under European law. In such cases, we put in place appropriate safeguards, including contractual commitments approved by the European Commission, on recipients of the data, to ensure that there is adequate protection for your personal data. For more information about the safeguards in place and to view a copy of such safeguards, please contact us using the details below.
8. Data security
We have implemented business physical and electronic processes and procedures to secure and safeguard the data that we collect. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security and you provide personal data at your own risk.
You are responsible of your username and password: keep them secret and safe.
If you believe your privacy has been breached, please contact us immediately on firstname.lastname@example.org
9. Data retention
We will retain your personal data for as long as your account is active or as needed to provide you services. If you close your account, we will retain your personal data for a period where it is necessary to continue operating our business effectively, to maintain a record of your transactions for financial reporting purposes or fraud prevention purposes until these purposes no longer exist, and to retain as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Information that you submit via Bufflunch Platforms is sent to and stored on secure servers located in the United Kingdom and other European Economic Area countries. This is necessary in order to process the information. Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside the European Economic Area and may be processed by staff operating outside the European Economic Area. By submitting information via the Bufflunch Platforms, you agree to this storing, processing and/or transfer.
10. Social media & public forums
Social Community Areas
You may access the Bufflunch Platforms, or the Bufflunch Platforms may contain connections to, areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content.
All of the information you post may be accessible to anyone with Internet access, and any information you include in your posting may be read, collected, and used by others.
Connecting through Social Networks
We offer social networking users the opportunity to interact with friends and to share on social networks. If you are logged into both the Site and a social network, when you use the Site’s social networking connection functions, you will connect your social network account with your Bufflunch account (this happens automatically, if the email addresses match). If the email addresses do not match, we ask you if you want to link them and you must validate that you control the accounts by logging in to your social network account. If you are already logged into the Site but not into your social network site, when you use the Site’s social network connection functions, you will be prompted to enter your social network website credentials or to sign up for the social network.
If you are not currently registered as a Bufflunch user and you use the Site’s social network connection functions, you will first be asked to enter your social network credentials and then be given the option to register and join Bufflunch. Once you register with us and connect with the social network, you will be able to automatically post recent Bufflunch activity back to your social network. Please refer to the privacy settings in your social network account to manage the data that is shared through your account.
11. Privacy practices and third parties
Bufflunch Platforms may contain links to third party services such as websites. We are only responsible for the privacy practices on our platforms. We recommend that you check the privacy statements of each and every other website that you visit.
This Privacy Statement only addresses the collection, processing and use (including disclosure) of personal data by us through your interaction with the Site. Other websites that may be accessible through links from the Site may have their own privacy statements and personal data collection, processing, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarise yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.
What are Cookies?
Cookies are unique identifiers, usually made up of small bits of text or code that are placed on your device. Cookies are widely used by website owners and their partners to help websites operate, work more efficiently, and personalize the experience for you.
Cookies may be placed on your device by Bufflunch, which are “first party” cookies. Cookies may also be placed on your device by a party other than Bufflunch, such as our Business Partners. These are “third party” cookies.
When we say “Business Partners”, we mean third parties with whom we conduct business, such as merchants, co-marketers, distributors, resellers, and other companies or organizations with whom we enter into agreements to support our business and operations, including advertising partners.
What are Cookies used for?
The first and third party cookies on our Site provide various functions:
Essential Cookies: These cookies are essential for our Site to work properly. They include, for example, cookies that make it possible for you to browse and use our Site, such as cookies that remember you have logged in to your Bufflunch account.
Functional Cookies: These cookies gather information about how visitors use the Site, monitor the Site’s performance, and are used to recognize and remember your preferences. If you agree to receive emails from us, we also use them to track responses to emails we send you, and to track whether you opened or deleted an email. Functional cookies can also be used to identify and remedy operational problems with the Site.
Advertising Cookies: These cookies record your online activities, including your activities on our Site, such as the pages visited, and the links and advertisements clicked. These cookies are used to provide an engaging and easy online experience that is tailored to your interests by delivering personalised advertising content. For example, if you view a particular offer on our Site, we may work with our Business Partners to show you that offer, or a similar offer, on other sites.
The advertising cookies we use on our Site are placed by either Bufflunch or our Business Partners. Any information collected by our Business Partners will be used in accordance with their own privacy policies. To learn more about advertising cookies, please visit http://www.youronlinechoices.com/uk/.
How do I manage Cookies?
These cookies are required to enable core functionality of the site, e.g. to keep you logged in as you navigate the site and to process purchases. These cookies are used to remember your preferences and analyse the usage of our Site. With these cookies enabled, we can provide you with the best experience and show you the most relevant deals, vouchers, products based on your interests. Without these cookies, we may not show you the most personalised selection of deals, vouchers or products and you may experience slower performance on the website. These cookies allow our authorised third-party partners to understand how you use the Site and the types of offers and products you are interested in most. Without these cookies, you cannot share any deals on social media and our advertising partners will not be able to show you the most relevant ads on third-party websites.
You may also disable certain cookies through your browser settings. In particular, you can disable these cookies on Apple Safari (as described here), Google Chrome (as described here), Internet Explorer (as described here) and Mozilla Firefox (as described here). Please check your browser settings for more information. Within each browser, you can select the option to clear all cookies and other browsing data.
If you use the Site after you have cleared all cookies from your browser settings, cookies may be placed on your device again. To avoid having these cookies placed on your device again, you can opt-out as described above or by installing an application on your browser, such as Ghostery or PrivacyBadger, to ensure certain cookies are not placed on your device.
For advertising cookies, in addition to the tool provided above, you can also visit http://www.youronlinechoices.com/uk/ and turn off certain cookies through the ‘Your Ad Choices’ page.
On mobile devices, you can also limit personalised advertising by reviewing and adjusting the setting provided by your device manufacturer, such as “Limit Ad Tracking” for Apple’s iOS devices or “Opt-out of interest-based ads” for Android. You can opt out of all personalised advertising or reset your advertising ID, so you only see personalised advertising related to what you look at from the point you reset it.
13. Contact Us
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by emailing email@example.com.
You can also reach us via postal mail at the following address:
Bufflunch Ltd, ATTN: Data Protection Officer, Lytchett House, 13 Freeland Park, Wareham Road, Poole, Dorset, BH16 6FA.