1. Introduction
Welcome to Gander Website/App. We value your privacy and are committed to protecting your personal information in accordance with the General Data Protection Regulation (GDPR).
This Privacy Policy explains how we collect, use, and safeguard your personal data when you access and use our Website and App. By using our Platform and Services, you consent to the practices described in this Privacy Policy.
2. Information we collect
When you use the Website/App, we may collect, use, store, transfer and otherwise process the following types data:
| Category of data | Description of data |
| Identity and Contact | Your name, email address and mobile telephone number. |
| User ID | A randomly generated user identification number used to identify you. |
| Location | Your precise current location or another specified location. We process this information based on your consent. |
| Social Media | Your login details for any social media pages you connect to through the App, including but not limited to, Facebook, WhatsApp and Instagram. |
| Profile | Optional 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 Enquiry | Information about you from emails and letters that you send to us, any conversations between us and any feedback you give to us. |
| Usage Information | When you access or use the Website/App, we may automatically collect certain information about your device, browsing actions, and patterns. This may include your IP address, browser type, referring/exit pages, and other technical information. |
| Cookies | We may use cookies and similar technologies to enhance your user experience, personalise content, and track usage patterns. You can control the use of cookies at the individual browser level, but disabling cookies may limit your ability to access certain features of the Website/App. |
| 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 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 2: How We Use your Information”. |
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.
3. How we collect personal data
We may collect different data from or about you depending on how you use the Website/App.
| Personal information | When you choose to access certain functionality within the App and are required to register an account with us, we collect personal information such as first name, last name, email address, password, location (either your current location or another chosen location), mobile phone number or Facebook login depending on the method you choose to use to sign up to the App. |
| Usage Information | When you interact with the Website/App, we may automatically collect technical data about your computer or mobile device, operating system, IP address, 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 Website/App using our cookies. The collection of data will also depend on the individual settings of your device and software. It is recommended to refer to the policies of your device manufacturer or software provider to learn about information they might share with us. For more information about cookies, please see our cookie policy (https://www.gander.co/cookies/). |
| Cookies | We may use cookies and similar technologies to enhance your user experience, personalise content, and track usage patterns. You can control the use of cookies at the individual browser level, but disabling cookies may limit your ability to access certain features of the Website/App. |
4. How 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 for, what personal data we use, the lawful basis that we rely on to use your personal data.
| Provision of Services | We use the collected information to provide and maintain Gander Website/App, fulfil your requests, and improve our services. |
| Enabling you to customise your profile and update your preferences in the App | We may use your personal information to customise your profile. This may include information about your dietary preferences and your allergies (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). |
| Marketing | We may use your contact information to send you updates on Gander, newsletters, marketing emails, or respond to your inquiries if you have given us permission to do so. You can opt-out of receiving marketing communications at any time by following the unsubscribe instructions provided in the email or emailing info@gander.co. |
| Analytics | We may analyse user behaviour and usage data to understand trends, evaluate the effectiveness of our content and features, and optimise our services. |
| Communication | We may use your contact information 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. Communicating with you if you have asked us a question, gave any feedback, or submitted a complaint. Performing our contract with you. |
| Legal Compliance | We may use your information to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. 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. |
5. Data sharing and disclosure
We may share your personal data with other organisations so we can provide our service to you via the Website/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.
| Service Providers | We may share your information with trusted service providers who assist us in operating the Website/App, conducting business, or servicing. These providers have access to your information only to perform tasks on our behalf and are obligated to maintain its confidentiality. These include our IT providers, customer service providers, email marketing providers, and software providers (Ex: Hubspot, Mailchimp, Resend, Mailgun, Onesignal). |
| Retailers | We may share information about you and other App users with the Retailers on an aggregated basis in order to provide you with better customer service and with more personalised loyalty schemes and offers (where you have signed up to them). 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. the Retailers will not be able to identify you from the data we give them. |
| Legal Requirements | We may also need to 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. |
| Business Transfers | In the event of a merger, acquisition, or sale of our business or assets, your information may be transferred as part of the transaction. We will notify you via email and/or prominent notice on Gander Website/App of any change in ownership or uses of your personal information. |
6. Where do we store your information?
We will not transfer or store your personal data outside of the United Kingdom (UK) or the European Economic Area (EEA), 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
- 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
If there are any other circumstances which would require us to transfer your personal data outside of the UK or the EEA, we will seek your consent to transfer your personal data outside of the EEA.
7. Data Security
We implement security measures to protect your personal information from unauthorised access, alteration, disclosure, or destruction.
However, please note that 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.
8. How long do we store your personal information?
Gander will retain your Personal Data collected from you while you are a user or partner of Gander. After this, we will keep your personal data for up to 5 years (or longer to comply with legal obligations). This is so we can:
- Communicate with you about any questions or complaints you may have after you have stopped using the App
- To comply with applicable legal, tax or accounting requirements
We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates to, and the purposes for which we collected the data.
9. Your rights under GDPR
You have certain rights if you are within the EU this includes:
- Right to access: This right allows you to obtain a copy of your personal data, as well as other supplementary information.
- Right to restrict processing: You have the right to restrict the processing of your personal data in certain circumstances.
- Right to rectification: You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Right to object to processing: The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your Personal Data. You also have the right to object where we are processing your Personal data for direct marketing purposes.
- Right to erasure: You have the right to ask us to delete or remove Personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.
For any complaint regarding the processing of your personal data, you can contact the Isle of Man Information Commissioner (https://www.inforights.im/).
10. Changes to this policy
We may update our Privacy Policy from time to time as our App develops and offers you more exciting features or if the law changes. We will notify you of any changes by posting the new Privacy Policy on this page. You can see when the Policy was last updated by checking the date at the bottom of this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from when they are posted on this page.
11. Contact us
If you have any questions about this Privacy Policy, please contact us by email at info@gander.co
or
Gander Limited
EuroManx House, Freeport
Ballasalla, IM9 2AP
Isle of Man