Last updated: 3rd March 2025
About POGO – Data Controller
RAZE ONLINE LIMITED, a company registered in England with company number 11322604, whose registered address is Ground Floor, Cooper House, 316 Regents Park Road, London, United Kingdom, N3 2JX, trading under the name “POGO” (“POGO”, “we”, “us”).
This privacy notice explains how we collect and process personal data when you use pogodonate.com (the “Platform”). It outlines your rights and our responsibilities under applicable data protection laws, including the UK GDPR.
Who This Notice Applies To
This notice applies to users who visit or interact with our Platform, including those who donate via our technology to access offers from commercial brand partners.
This Platform is intended for users aged 16 and older.
How We Use Your Personal Information
We process personal information for the following purposes:
- To process donations made via the Platform
- To send donors discount codes unlocked through donations (on the basis of legitimate interest)
- To send marketing communications to users who have opted in
- To ensure platform functionality and security
- To comply with legal obligations and detect misuse or fraud
- To analyse aggregate usage patterns and improve our services
What Personal Data We Collect
Depending on how you interact with us, we may collect:
- Identity and Contact Data: Name and email address
- Transaction Data: Charity selected, donation amount, limited payment information (e.g. last four digits of your card), handled via our payment processor (Stripe)
- Usage Data: IP address, browser type, device data, referring URLs, page interactions, visit duration
- Correspondence Data: Information you provide via contact forms, emails, or other communication
We do not collect special categories of personal data or information about criminal convictions and offences.
Lawful Basis for Processing
We rely on the following legal bases:
- Legitimate Interests: Processing donations, sending discount codes, platform protection, analytics, and record-keeping
- Consent: For marketing emails and where legally required (e.g. cookies)
- Legal Obligation: Compliance with applicable laws and regulations
Marketing Communications
If you choose to opt in, we may send you marketing emails about other brand discounts and future POGO campaigns. You can unsubscribe at any time via the link in the email or by contacting info@pogodonate.com. We use Mailchimp to manage these communications.
Data Sharing
We do not share your email address or any personal data with third parties – e.g. our brand or charity partners.
We only share your personal data with:
- Our internal staff and contractors
- Service providers such as Stripe (payments), AWS (hosting), and Mailchimp (marketing)
- Law enforcement or regulatory bodies where required by law
We may share aggregated, anonymised campaign performance data with commercial partners. This data cannot identify you.
International Data Transfers
Your data may be stored or processed outside of the UK or EEA using providers such as AWS and Mailchimp. Where applicable, we use Standard Contractual Clauses and Data Transfer Agreements to ensure your data remains protected in line with UK GDPR requirements.
Data Retention
We retain personal data:
- For up to 2 years from the date of donation or last interaction
- Longer where required by law or in connection with legal claims
You may request deletion of your data at any time, unless we are legally required to retain it.
Cookies
We use cookies to improve user experience. These include:
- Essential Cookies: Enable platform functionality
- Analytics Cookies: Help us understand usage (e.g. via Google Analytics). These require user consent.
You can manage cookie preferences via your browser. Learn more at www.allaboutcookies.org.
Your Rights
Under UK GDPR, you have the right to:
- Access your personal data
- Correct inaccurate data
- Request deletion of your data (“right to be forgotten”)
- Restrict or object to certain types of processing
- Request data portability (in applicable cases)
To exercise your rights, contact us at info@pogodonate.com.
Contacting Us
If you have questions or concerns, contact us at:
Email: info@pogodonate.com
We encourage you to contact us first before approaching the UK Information Commissioner’s Office (ICO).