POGO Privacy Notice
About POGO – data controller
RAZE ONLINE LIMITED, a company registered in England with company number 11322604, whose registered address is Third Floor, Unit 3, The Exchange, Brent Cross Gardens, London, United Kingdom, NW4 3RJ, trading under the name “POGO” (hereinafter referred to as “POGO”).
This privacy notice will inform you as to how we look after your personal data when you visit www.info.pogodonate.com (the “Platform”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Changes to the privacy notice
This version was last updated on 22/06/21. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This privacy notice aims to give you information on how we collect and process your personal data through your use of this Platform, including any data you may provide through this Platform.
This Platform is intended for any user aged 16 and older.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK’s independent supervisory authority for data protection issues (Home | ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
How we use your personal information
We use personal information in order to promote and provide our services, to ensure the security of our website, and to run our business. We have set out below more information on:
the categories of personal information that we collect;
the specific ways in which that personal information is processed by us;
the legal bases which permit us to do this;
the types of partners with whom we share your personal information; and
your rights with respect to your personal data.
In some cases where we ask for your personal information, we do so in order to provide our services and will only collect and process any such personal information for the purposes which it is collected for and any other compatible purposes. If you do not provide that personal information, we may not be able to process your personal data where it is required for the purpose of providing our services or any other purpose communicated to you.
What personal information do we collect?
We collect and process different personal information according to the context in which you interact with us and the Platform. This information includes:
Type of interaction Personal information collected
POGO Platform Users (people who use our Platform, including the restricted user account)
We may process: your name; marital status, address; email address; date of birth; gender; telephone number; records of participation in our promotional campaigns and prize draws; your marketing preferences, including any consents you may have given us (“identity and contact data”).
Once you access our Platform and register as Platform user, we may process: your login details; records of your use of the Platform, including pages accessed, time and duration of usage; information related to the browser or device you use to access the Platform, including IP address and related identifiers; and any other information you provide to us through contact forms, live chats and/or other correspondence (“profile data”).
We may process your transaction data such as: bank account details, payment methods, time, place, charity donated to; amount and any other associated transaction information (“transaction data”). We may also process your bank account and payment details data (“financial data”).
Anyone else we may be dealing with, such as Platform visitors, suppliers, sub-contractors, commercial partners and correspondents
We may process data about your use of our Platform and services; geographical location; internet protocol (IP); time zone settings and location; browser operating system; any other technology you may use to access the Platform; browser type and version; operating system; referral source; length of visit; page views and website navigation paths; and information about timing, frequency and pattern of your Platform use (“usage data”).
We may process information contained in or relating to any enquiry or communication that you send to us or that we send to you. Such data may include: communication content and metadata associated with the communication; any contact details you may provide to us such as your name, email address, phone number, job title, address, social media username and feedback surveys (“correspondence data”).
We also collect, use and share aggregated data such as statistical data for any purpose (“aggregated data”). Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Aggregated non-personal data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our Platform.
We do not collect any special categories of personal data about you, nor do we collect any information about criminal convictions and offences.
How we collect personal data
Most of the data we collect is via direct interactions with you. Please see the table below to learn more about how we collect your personal data.
You may give us your identity and contact; profile; correspondence, usage and financial data by submitting your information to us via the Platform, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o create a user account;
o make a POGO one-off donation;
o make a POGO chance donation;
o request marketing to be sent to you; or
o give us feedback or contact us.
We may receive your financial data from the following sources:
o directly from you;
o from providers of technical, payment and delivery services;
o from the third party services providers, such as payment processing services providers.
o directly from you;
o from providers of technical, payment and delivery services; and
o from the third party providers in respect of the particular services provided to you.
How do we use your information – lawful purposes for processing
We use your information as follows:
A. As required by us to conduct our business and pursue our legitimate interests, in particular:
· to establish and manage your POGO account and your profile;
· to increase and maintain the safety and security of all personal data which you provide to POGO via the Platform or otherwise;
· to prevent misuse;
· to administer and protect our business, including troubleshooting, data analysis and system testing;
· to perform analytics of anonymised personal data (including market and consumer research and trend analysis);
· for the purposes of billing reconciliation, collection, auditing, accounting;
· to protect against and prevent fraud and theft and other criminal activities;
· to comply with and enforce applicable legal requirements, relevant industry standards and policies;
· in order to protect your vital interests or those of another individual;
· for the purposes of record-keeping and hosting, back-up and restoration of our systems;
· to provide dynamic content within our services on the Platform;
· to let you know about our services by post, email, and phone in accordance with your marketing preferences and law relating to direct marketing;
· to provide targeted advertising for our other products and services that we think may be of interest to you, based on how you use our website, products and services;
· to analyse how you use our services so we can improve our levels of service and develop future products and services, including through the use of surveys and research and concept studies;
· to ensure that our Platform and information technology systems and protected; and
· to place cookies on your device(s) and use similar technologies as described in the cookies section below.
B. As required by you and/or us on the basis of your consent
· to create your user profile;
· to register your user profile;
· to provide our services;
· to collect donations;
· to allow you to interact with certain third-party products or services such as our commercial brand partners;
· to contact you with regards to prize draws, discounts and your donations;
· to establish and manage your POGO account and profile;
· to process and fulfil requests in connection with our services such as provide a discount to you from one of our partner brands;
· to enable your access to our Platform; and
· to identify and authenticate you so you may access and use the Platform.
C. For purposes which are required by law
We may process your personal information in order to comply with legal obligations to which we are subject.
How will we share your information:
We share your personal details:
· with people within our organization, such as employees and contractors) who are involved in carrying out the processing described above; and
· with third party service providers and business partners who process your information on our behalf for the purposes above – such as IT hosting providers, payment service providers, commercial brand partners and other specialists and professionals retained by us.
We will also share your personal information:
· if we think this is necessary to in order to protect the rights, property, or safety of our business, our employees, our partners, or our customers. This includes sharing information for the purposes of fraud protection;
· with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy; and/or
· with government authorities and/or law enforcement officials if required by law.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Giving and withdrawing your consent and updating your personal information
Where your consent is required for us to process your personal information, we will ask for your consent at the point at which you provide your data. You have the right to withdraw that consent at any time. You can also update your personal information at any time. If you wish to do either, contact us at firstname.lastname@example.org.
Storing your personal information; transfers outside the UK
We may use our secure servers to store your personal data. We take appropriate physical, electronic and procedural measures to ensure that we keep your information secure, accurate and up to date in accordance with this policy.
We also use Amazon Web Services (cloud) for the purpose of storing personal data. Amazon Web Services (Cloud) servers may be located in the US and anywhere else in the world. Amazon is responsible for security of its cloud servers. Amazon implements security measures that we will implement and operate. At all times we, as data controller, remain responsible for security of all your personal data.
Your personal information may be stored and processed outside of the country where it is collected, including outside of the UK and the European Economic Area (EEA). When transferring information to countries which are not subject to the relevant European Commission adequacy decision, we will ensure that appropriate and suitable safeguards and technical measures are in place to protect your personal data. To do this, we make use of statutory standard contractual clauses, or we will implement other similar measures required by laws around the world. If you would like further information about this, please contact us at email@example.com
We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal data for marketing purposes. This includes keeping a record of your request indefinitely so that we can respect your request in future.
We may retain your personal data longer:
· to comply with the laws;
· to protect your vital interests or those of another individual; or
· in connection with any legal claims (to the extent those claims are continuing after the end of the relevant retention period).
Finally, we may create anonymised or aggregated records relating to demography or the use of our website or services, from which no individual is identifiable. We may retain those records, which are not personal data, indefinitely.
Personal data relating to someone else
Prior to providing to POGO any personal information concerning another individual, you must (unless we agree otherwise):
· obtain their permission (where possible) to share their personal information with us in accordance with this policy.
Under certain circumstances, you have rights under the relevant data protection laws in relation to your personal data. Please see below the summary of your rights:
• right to rectification:
If your personal information is incorrect or incomplete any way, you may notify a person dealing with your matter and where inaccurate or incomplete, we will correct it without delay.
• right of access:
· You may request a confirmation from us that we are processing your personal data;
· access your personal data held by us and request a copy (unless providing a copy adversely affects the rights and freedoms of others);
· obtain certain information about how we process your personal data, categories of personal data processed, recipients or categories of recipients who receive personal data from us; and
· how long we store your personal data for and the criteria we use to determine retention periods.
• right to be informed:
· How your personal data is being processed;
· how long it will be stored for;
· the legal basis for processing;
· recipients (or categories of recipients) of your personal data; and
· whether personal data must be provided under statute or for another reason and the consequences of not providing the personal data to ensure the fair and transparent processing of your personal data.
• right to restrict processing under certain circumstances:
· if you contest the accuracy of your personal data, we may restrict its processing, until we can verify its accuracy;
· if the processing is unlawful;
· if we no longer need to process your personal data, unless we still need your personal data for the establishment, exercise, or defense of legal claims; and
· if you object to processing that relies on public interest or our (or third party’s) legitimate interest as the lawful processing ground.
• right to data portability:
· Right to receive from us a copy of your personal data in commonly used and machine-readable format and store it for further use on a private device; and
· right to transmit personal data to another third party, or have your personal data transmitted directly from one third party to another where technically possible.
• right not to be subject of automated processing:
· Right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
• the right to object to processing:
· You may object to processing of your personal data. We will stop processing your personal data once notified by you, except if we can demonstrate a compelling legitimate ground for processing the personal data that overrides your request; or processing is necessary to exercise or defend legal claims.
You can contact us by email at firstname.lastname@example.org in relation to any of the rights described in this paragraph, or if you have any questions regarding this privacy notice.
What are cookies?
Cookies are small text files that are sent to your computer, mobile phone or tablet when you visit a website. Cookies stay on your device and are sent back to the website they came from when you visit it again.
Cookies collect data and send it to us while you use the Platform. These are written into mobile apps and web pages that you go to on your device and can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
You can choose to accept or decline cookies, and the most effective way to do this is through the settings on your web browser. If you disable or decline cookies, you may not be able to access some parts of the Platform, and some features may not function properly or be available to you.
We use the following types of cookies:
• Strictly necessary cookies: are essential in order to enable you to move around the Platform and use its features.
• Analytics cookies: it is important for us to understand how you use the site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping us to improve the site and your experience of it.
• Performance cookies: collect information about how visitors use our Platform. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform.
• Functionality cookies: are used to provide services or to remember choices you make so we can personalise our content for you.
● Persistent cookies: are those which remain on your computer or device for a predetermined period and are activated each time you visit the Platform.
● Session Cookies: are temporary and only remain on your computer or device from the point at which you visit the site until you close your browser. Session Cookies are deleted when you close your browser.
Some of the cookies which we may use are stored by our site which you are visiting directly (“first party cookies”) and others are created by domains other than our Platform (“third party cookies”).
Some of the cookies that you may find on your browser (depending on settings) after navigating to our Platform are as set out below:
_ga (cookie), duration (2 years), strictly necessary first party cookie to distinguish users
_gid (cookie), duration (24 hours), strictly necessary first party cookie to distinguish users
_ ga, duration (2 years), strictly necessary first party cookie to persist session state
gac_gb_, duration (90 days), strictly necessary third party cookie necessary for Google Analytics to read activity.
Additional cookies may be added, and we may update or remove the cookies below from time to time.
How do I change my cookie settings?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Apple Safari
To find information relating to other browsers, visit the browser developer’s website.
Third party links
This policy does not cover any third-party links on our website that link to other websites. We therefore encourage you to read the privacy statements on the other websites you visit.
Additional points to keep in mind
• Multiple Users
If more than one person uses your device, the choices set up by other people will apply to you as well unless you change them. For example, if you share a computer with your family, you may see ads based on sites they have visited as well as sites you have visited.
• Cookies with more than one use
Managing cookies choices in your browser
You can turn off or delete cookies in your browser. If you do this it may affect sites that use similar cookies to us.
Cookie choices you set in your browser replace any you set on a single website. For instance, if you run an ad blocker on your browser, you won’t see ads that are tailored to you, even if you have turned on marketing cookies.
• Email tracking
We track emails to help us improve the communications we send. We use small images called pixels within our emails to tell us things like whether you opened the email, how many times and the device you used. We may also set a cookie to find out if you clicked on any links in the email. The image stays in the email but leaves nothing else on your device.
• How to stop email tracking
You can stop this by closing the email before you download any images or click on any links. You can also set your browser or email program to restrict or block our emails. Sometimes your browser or email program setting will automatically accept cookies. For more details on this, you will need to read the instructions for your browser, email program or device.
We can be reached by email at email@example.com