1. Who are we?

Welcome to the Gander (“Gander” or “App”) App and/or website privacy policy. Gander has been developed by Gander Limited (“Argadnel”, “we”, “us”, “our”). In order to use the App, you must accept our Terms and Conditions which are available here (https://www.gander.co/terms-and-conditions). For more information about Gander, please visit our website (https://www.gander.co/) (“Website”).

2. How does Gander work?

We have developed the Gander smartphone application for iOS and Android devices which is available for download from iTunes/Apple Store (the “App”). The App provides aggregated information to users of the App (“you” or “your”) about price reductions, product promotions and loyalty scheme offers available from retailers in the food and grocery sector (the “Retailers”), once installed on your mobile device.

The App includes a number of features such as, creating a user profile to filter certain products depending on your dietary preferences and allergy requirements. More information about the features offered via the App can be found in the terms and conditions (https://www.gander.co/terms-and-conditions/).

We are committed to protecting and respecting the privacy of the users of the App. This privacy policy (“Privacy Policy”) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the Privacy Policy carefully to understand how we will use your personal data. For the purpose of data protection legislation in the UK, we are the controller of your personal data.

3. How can you contact us?

If you have any questions about your personal data, how we look after it or if there are any changes to your personal data, please:

• Email us at privacy@gander.co (mailto:privacy@gander.co); or
• Write to us at Gander Limited, Euromanx House, Freeport, Ballasalla, Isle of Man, IM9 2AP

4. What data do we collect about you?

When you use the App, we may collect, use, store, transfer and otherwise process the following types data:

Category of dataDescription of dataIdentity and ContactYour name, email address and mobile telephone number.User IDA randomly generated user identification number used to identify you.LocationYour precise current location or another specified location.Social MediaYour login details for any social media pages you connect to through the App, including but not limited to, Facebook, Whats App and Instagram.ProfileOptional data about you that you can choose to input in the App in order to create a profile about you and your preferences. This may include information about your dietary preferences and information about your allergies. We will only collect this type of information about you with your explicit consent.Feedback and EnquiryInformation about you from emails and letters that you send to us, any conversations between us and any feedback you give to us.Research

Statistical information we collect about you and other App users, to help us and our Retailers understand the general trends of the way you in which interact with Retailers via the App. This may include collecting information such as the types of products you are interested in and when, how and where you make your purchases with the Retailers.

When we combine your information with information about other App users, we make sure that you cannot be identified from this group of information. This “aggregated” data is anonymous as specific individuals cannot be identified from this dataset and therefore will not be considered personal data. We may share this aggregated data with the Retailers for the purposes set out in section 6

The law treats some types of personal data about you as “special” and such data requires more protection because of its sensitive nature. This includes information about your race, religion, health, sex life, sexual orientation or criminal offences. For example, information that you may choose to provide to us about your dietary preferences or allergies will be health data and will fall under this special category of personal data. We will only collect or use this type of personal data (a) with your explicit consent or (b) if the law requires us to do so.

5. How do we collect personal data about you?

We collect your personal data in different ways, including:

• Directly from the AppWe will collect your personal data directly from the App when you choose to access to certain functionality within the App and are required to register an account with us. This will include providing us with your name, your location (either your current location or another chosen location) and either your email address, mobile telephone number or Facebook login depending on the method you choose to use to sign up to the App. You may choose to provide us with other personal data so that we can create a profile about you based on your preferences.
• Automated technologiesWhen you interact with the App, we may automatically collect technical data about your mobile device, browsing actions and patterns. We collect this personal data using cookies and other similar tracking technologies. We may also receive technical data about you if you visit other websites through the App using our cookies. For more information about cookies, please see our cookie policy (https://www.gander.co/cookies/).
• Third partiesWe may receive personal data about you from other parties and/or from public sources, as set out below:

6. How do we use your personal data?

We will only use your personal data where we have a valid lawful basis to do so. We have included a table below which lists all the ways in which we use your personal data and the lawful bases we rely on to do so.

Where we mention “legitimate interests”, this is the lawful basis we rely on when we feel that it is necessary to use your personal data for a reason which is in our and/or your interests and which does not unfairly affect your rights over your personal data.

What we use your personal data forWhat personal data we useThe lawful basis that we rely on to use your personal data1. Providing you with our service through your App

Including providing you with:

• Information about price reductions on Retailer products
• Your name;
• Your location (either your specific current location or another chosen location);
• Your telephone number/ your email address/ your Facebook login (depending on which method you choose to register an account with us)

Performing our contract with you.

2. Enabling you to customise your profile and update your preferences in the App

Enabling you to input certain information about yourself in the App in order to create a customised profile about you and your preferences. This may include information about your dietary preferences and information about your allergies, which the law treats as special category personal data. This information will help us tailor the information we send to you on Retailer products and the personalised offers we send you from Retailers (if you have provided your explicit consent to receive these offers).

Profile data

Your consent. If you change your mind about this, you can withdraw your consent at any time by emailing privacy@gander.co (https://www.gander.co/privacy/mailtoprivacy@gander.co)

3. Improve the Gander service for you and other App users

Improve the service we give to our App users by looking at details of the information you and other App users view with the Retailers. The information about you and other App users will be grouped together in a way that you can no longer be recognised from the group of information.

We will share this information with the Retailers to help them understand you better and provide you with a better customer experience. Gander and the Retailers will not be able to identify you from the information we give them.

• Information about the information you view with our Retailers;
• Our legitimate interests and the Retailers’ legitimate interests of understanding you better to provide a better service for the purposes of benefitting you.

4. To send you marketing emails if you want to receive them

We will only send you marketing emails if you have given us permission to do so. You can choose to get all or some of the following different types of marketing emails:

• New features in the App; and
• Updates on Gander generally.

Your email address

Your consent. If you change your mind about this, you can withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of each email or by emailing privacy@gander.co.

If you choose to withdraw your consent to receiving these marketing emails, we will still be able to send you emails that are necessary for our relationship with you as a Gander App user.

5. To manage our relationship with you as an App user

This will include:

• Letting you know if anything about the Gander service changes or this policy changes in an important way; and
• Communicating with you if you have asked us a question or made a complaint with us
• Your email address;
• Information you tell us when you send us a question or make a complaint; and
• Information you tell us when you give any feedback about us
• Performing our contract with you;
• To comply with our legal duties; and/or
• Our legitimate interests of understanding you better to provide a better service to you for your benefit.

6. Complying with legal and regulatory requirements

We are required to comply with certain legal and regulatory requirements and may process your personal data for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject.

• Your name;
• Your email address;
• Your residential address; and
• Your telephone number

As required by the regulators and/or law enforcement agencies.

• To comply with our legal duties

We will only use your personal data for the reasons we have set out above. If we need to use your personal data for any other reason, we will let you know and tell you the reason along with the relevant lawful basis, unless the law prevents us from doing so.

7. Who do we share your personal data with?

We may share your personal data with other organisations so we can provide our service to you via the App and comply with our legal duties. We have set out below who these organisations are and the reasons for sharing your personal data with such organisations.

• Retailers – we will share information about you and other App users with the Retailers on an aggregated basis so they can learn more about you and other App users in order to provide you with a better customer service and provide you with more personalised loyalty schemes and offers (where you have signed up to them) – the Retailers will not be able to identify you from the data we give them; and
• Our service providers – we need to share information with organisations which support the App that you use including our IT providers, customer service providers and email marketing providersYou can ask us for more information about these organisations by contacting us using the details at the top of this policy.

We may also need your share your personal data to comply with the law; to enforce our Terms and Conditions; to protect the rights, property or safety of us, other App users or other individuals/organisations.

8. Where do we store your information?

We will not transfer or store your personal data outside of the European Economic Area (EEA) (or the UK to the extent the UK is no longer part of the EU), except to selected third parties that we have instructed to help us provide the services to you

If we do transfer or store your personal data outside of the EEA, we will ensure we have put adequate measures in place in order to protect your personal data to an equivalent data protection standard as in the UK and the EEA.

We will only share your personal data with countries and organisations that:

• The European Commission has deemed as having equivalent data protection laws as in the EEA;
• We have entered into a contract with which include certain requirements to make sure your personal data is protected to equivalent standards as in the EEA and the UK – please click here for a link to the standard contractual/data protection clauses; or
• Have chosen to comply with a set of rules called the Privacy Shield framework which includes data protection standards for transfers of personal data between the United States and the EEA – please click here for more information about the Privacy Shield for US companies.

If there are any other circumstances which would require us to transfer your personal data outside of the EEA (or the UK to the extent the UK is no longer part of the EU), we will seek your consent to transfer your personal data outside of the EEA.

You can ask us for more information about where we may transfer or store your personal data and how we will take steps to ensure your personal data is protected by using the contact details in section 3 of this policy.

9. How do we keep your personal data secure?

We will ensure we put security measures in place to protect your personal data from being destroyed, lost or shared with somebody that should not see it. However, we cannot guarantee your personal data will be free from every security risk that may be possible when your information is sent to and from the App.

The App may include links to third-party websites which may collect your personal data. We have no control over what these websites do with your personal data. Please check the policies on these websites which will tell you what they do with your personal data.

10. How do we use cookies?

We use cookies or other similar technologies to capture certain data when you interact with the App. For further information on our use of cookies, please see our cookie policy at [insert link to cookie policy

11. How long do we keep your information for?

We will only keep your personal data for as long as is necessary for us to do so for the reasons we collected it for in the first place.

Generally, we will keep your personal data for as long as you are an App user. After this, we may keep your personal data for up to 6 years (or longer where the law requires). This is so we can:

• Communicate with you about any questions or complaints you may have after you have stopped using the App; or
• To comply with the rules on accounting, reporting or any other law.

If you want further information on how long we keep your personal data, please contact us using the details set out in section 3 of this policy.

12. What are your rights in relation to your personal data?

As a result of us collecting and processing your personal data, you may have the following legal rights:

• To access the personal data we hold about you and request a copy of it;
• To ask us to correct your personal data if it inaccurate or incomplete;
• To ask us to delete your personal data where we do not have a compelling reason to continue to process your personal data in such circumstances;
• To ask us to stop using your personal data in certain circumstances where there is no need for us to continue processing it in certain circumstances;
• To ask us to only use your personal data for certain things if: it is not accurate; it has been used unlawfully; or it is not relevant for the purposes it was initially collected for; and/or
• To ask us to stop using your personal data to send you marketing emails.

If you want to exercise any of the rights listed above at any time, please contact us using the details in section 3 of this policy.

13. How can you make a complaint?

You also have the right to make a complaint about how we have used your personal data to:

• Us – by contacting us by email or post using the details in section 3 of this policy and we will always try to help you with your problem in the first instance.

If you’re still not happy with how we have dealt with your complaint, you can contact:

• A data protection regulator – this is the Information Commissioner’s Office in the UK and you can make a complaint at https://ico.org.uk/make-a-complaint/ (https://ico.org.uk/make-a-complaint/).
• The UK courts – to seek a remedy if you think that your rights in relation to your personal data have been breached.

14. Changes to this Privacy Policy

We may need to change this Privacy Policy as our App develops and offers you more exciting features or if the law changes. We will let you know if any important changes are made, otherwise, we will always display the latest version of our policy within our App.