Privacy & Security

This is the [Client] Online Mall Privacy Policy that discloses the privacy practices for the [Client] online Mall. The [Client] Online Mall is owned and operated by Collinson (Latitude) Limited, Cutlers Exchange, 123 Houndsditch, London EC3A 7BU, United Kingdom (“We” or “us”). If you have any questions about this Privacy Policy, please feel free to contact us at this address.

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we treat any personal data we collect and process when you use our website, services or products.

1. Collection and processing of your personal data

We only collect and process your personal data if:

You have agreed to it (e.g. while logging into the website); or
It is necessary in order for us to be able to provide our service or product, which you have agreed to; or
It is necessary for compliance with our legal obligations as providers of the [Client] Online Mall; or
We have legitimate reason to do so, such as for fraud prevention or debt collection.

2. What types of personal data we handle

We collect and process the personal data that you as provide when interacting with us directly either online or via email (e.g. for customer service purposes), phone or post.

Such personal data may include the following:

First name and surname;
Email address;
Gender
Country of residence;
Unique identifier information (e.g. your membership number);
Some details provided by your device such as IP address, device ID, device type, and location data;
Transaction data including a transaction ID, transaction date and transaction timestamp, transaction amount and participating merchant ID (“Transaction Data”)

3. How we use your personal data

We may use the personal data we collect and process about you in order to:

Provide you with access to our website;
Provide the services or products you request;
Provide you with information you have requested, including without limitation, service emails concerning your purchase;
Respond to any enquiries from you regarding our products and services;
Where you have agreed, provide you with information about certain other goods and services which we believe may be of interest to you;
We may collect information on your activity on our website through monitoring your navigation and use of tools and functions available on our website. This non-personal information may be used in aggregated format to enable us to analyse the use of the website and to enhance the services offered (e.g. navigation experience, selection of retailers in our website);
Meet our legal and regulatory obligations;
Detect and prevent fraud.

Where you have agreed to receive card-linked offers, We may use Transaction Data:

to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a statement credit or an offer;
to share with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or points should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
to provide participating merchants or third party service providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and third party service providers to assess the results of their campaign;
to create a record of the transaction data and thereafter maintain and use data in connection with operating the program;
to conduct analysis for the improvement and optimization of the program; and
to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

Transaction Monitoring – By registering a payment card in connection with transaction monitoring, you authorize us to share your payment card information with Mastercard, Visa and/or American Express so they are aware you have enrolled. You hereby authorize Mastercard, Visa and/or American Express to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Mastercard, Visa and American Express to share such transaction details with us to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by navigating to your list of registered cards under the ‘My Account’ tab in the [Client] online mall.

4. Personal data sharing and transferring

We will not share your personal data with anyone else unless you agree to this, or such sharing is necessary to fulfil our contract with you, or we are legally allowed or required to do so. Moreover, your personal data will only be shared with selected organisations which comply with our security procedures and policies.

Organisations we may share your personal data with include:

Another member of our group of companies where they help provide our services to you;
Our service providers and subcontractors, where they us help provide our services to you;
To a regulating body or other authority where we need to comply with a regulatory or legal obligation;
Fraud prevention or debt collection organisations when required to protect our legitimate interests.
Some of those organisations may be based in a country outside the European Economic Area or where different data privacy laws apply. We will only transfer your personal data to that country if they ensure an adequate level of protection of your rights and freedoms, or you have given us your consent, or that organisation is contractually bound to meet European Economic Area data protection law.

We will not sell your personal data to anyone.

5. Personal data protection and storage

Personal data collected and processed in accordance with this Privacy Policy is stored on secure servers located in the United Kingdom (primary servers) and United States, Hong Kong and Australia (replicas).

We handle your personal data in accordance with adequate and reasonable procedures and technologies in order to maintain and protect its security, availability, confidentiality and integrity, and prevent its unlawful or unauthorised processing, accidental loss or damage, from its collection until its destruction.

Where personal data is transmitted across the internet, it will be encrypted.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of your personal data, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6. Personal data disposal and retention

We will only keep your personal data for as long as it is needed for the purposes for which it was collected and we will remove from our systems all personal data which is no longer required.

We will only retain your personal data for 12 months since your last used our services or after this time where we are required to do so, in order to meet a regulatory or legal obligation.

7. Use of cookies

We use cookies on our website in order to improve your user experience by enabling our website to 'remember' you, either for the duration of your visit (using a 'session cookie') or for repeat visits (using a 'persistent cookie'). We may also use cookies to enable us to target our services or products based, for example, on your location and/or browsing habits.

Please click here to read our Cookie Policy which explains what we do and how you can alter your cookie settings.

8. Your rights

You have the right at any time and free of charge to access your personal data in the following ways:

Request a copy of the personal data we hold about you. We may charge a reasonable fee to provide further copies, and can refuse to give you this information if your requests are clearly unjustified or excessive;
Have your personal data corrected if it is inaccurate or incomplete;
Request the deletion of your personal data where it is no longer necessary for us to keep it for the purpose for which it was originally collected or processed, unless we have a legal or regulatory obligation to retain the personal data;
Restrict further processing of your personal data. Where you have previously entered into a contracted service or product with us, this may imply cancelling the contracted service or product;
Withdraw your agreement to direct marketing, including profiling;
Obtain and reuse your personal data for your own purposes subject to certain conditions of portability.

9. How to contact us

For the purposes of data protection legislation, [Client] is the data controller.

10. Other websites

Our website may contain links to other websites. This Privacy Policy only applies to our website, services and products so when you link to other websites, you should read their own privacy policies.

11. Changes to our policy

We keep our Privacy Policy under regular review and we will make any new versions available on our website. This Privacy Policy was last updated on [Date].