1. DEFINITIONS AND INTERPRETATION
The following definitions shall apply in this agreement.
an account required for a User to access and/or use certain areas of the Site, as detailed in clause 4;
2. INFORMATION ABOUT US
2.1 The Site, www.info.pogodonate.com, is owned and operated by Raze Online Limited, a company registered in England under 11322604, with registered address is Third Floor, Unit 3, The Exchange, Brent Cross Gardens, London, United Kingdom, NW4 3RJ, trading under the name “POGO”.
2.2 For further details in relation to POGO’s services, please see our FAQ’s here.
ACCESS TO OUR SITE
3.1 Access to the Site is free of charge.
3.2 It is your responsibility to make any and all arrangements necessary in order to access the Site.
3.3 Access to the Site is provided “as is” and on an “as available” basis. POGO may alter, suspend or discontinue the Site (or any part of it) at any time and without notice. POGO will not be liable to you in any way if the Site (or any part of it) is unavailable at any time and for any period.
4.1 Certain parts of the Site (including the ability to purchase services from POGO) may require an Account in order to access them.
4.2 You may not create an Account if you are under 16 years of age. If you are under 16 years of age and wish to use the parts of the Site that require an Account, your parent or guardian should create the Account for you and you must only use the Account with their supervision.
4.3 When creating an Account, the information you provide must be accurate and complete. If any of your information changes at a later date, it is your responsibility to ensure that your Account is kept up-to-date.
4.4 POGO requires that you choose a strong password for your Account, consisting of [8 minimum number lowercase characters, 1 minimum number uppercase characters, 1 minimum number digits, 1 minimum number special characters]. It is your responsibility to keep your password safe. You must not share your Account with anyone else. If you believe your Account is being used without your permission, please contact POGO immediately at [firstname.lastname@example.org]. POGO will not be liable for any unauthorised use of your Account.
4.5 You must not use anyone else’s Account.
4.6 Any personal information provided in your Account will be collected, used, and held in accordance with your rights and POGO’s obligations under the law, as set out in clause 19.
4.7 If you wish to close your Account, you may do so at any time. Closing your Account will result in the removal of your information. Closing your Account will also remove access to any areas of the Site requiring an Account for access.
4.8 If you close your Account, any user Content you have created on the Site will be deleted.
5. POGO’S OBLIGATIONS AND DEDUCTION OF FEES
5.1 POGO undertakes to:
5.1.1 use its reasonable commercial endeavours to ensure that Content on the Site in relation to Benefits and Donations is accurate;
5.1.2 pass any Donations made on the Site to the relevant nominated Charity, minus the Platform Fee.
188.8.131.52 Platform Fee is calculated as; POGO Fee (20% of donation) + Stripe’s Fee (1.4% of donation + £0.20). This is capped at £1.00 total, meaning on donations over £4, POGO’s donation fee is less than 20%.
184.108.40.206 When processing a payment from a non-eu card, the Stripe fee will be 2.9% + £0.20
5.1.3 inform Brands of any relevant Benefits and, to the extent reasonably commercially possible, ensure that such Brands extend all Benefits earned by Users to such Users.
5.2 You acknowledge that the Platform Fee (made up of POGO’s Fee + Stripe’s Fee) will be deducted from any Donations.
5.3 It is the customers responsibility to ensure they have carefully checked the conditions of the offer. If there is an issue with the discount code unlocked, POGO will use its reasonable commercial endeavours to resolve the issue.
6. INTELLECTUAL PROPERTY RIGHTS
6.1 With the exception of User Content (see clause 8), all Content included on the Site and the copyright and other intellectual property rights subsisting in that Content, unless specifically labelled otherwise, belongs to or has been licensed by POGO. All Content (including User Content) is protected by applicable United Kingdom and international intellectual property laws and treaties.
6.2 Subject to clauses 7.3 and 7.6 you may not reproduce, copy, distribute, sell, rent, sub-licence, store, or in any other manner re-use Content from the Site unless given express written permission to do so by POGO.
6.3 You may:
6.3.1 access, view and use the Site in a web browser (including any web browsing capability built into other types of software or app);
6.3.2 download the Site (or any part of it) for caching;
6.3.3 print page(s) from the Site;
6.3.4 download extracts from pages on the Site; and
6.3.5 save pages from the Site for later and/or offline viewing.
6.4 POGO’s status as the owner and author of the Content on the Site (or that of identified licensors, as appropriate) must always be acknowledged.
6.5 You may not use any Content saved or downloaded from the Site for commercial purposes without first obtaining a licence from POGO (or our licensors, as appropriate) to do so. This does not prohibit the normal access, viewing and use of the Site for general information purposes whether by business users or consumers.
6.6 Nothing in these Terms limits or excludes the fair dealing provisions of Chapter III of the Copyrights, Designs and Patents Act 1988 ‘Acts Permitted in Relation to Copyright Works’, covering in particular the making of temporary copies; research and private study; the making of copies for text and data analysis for non-commercial research; criticism, review, quotation and news reporting; caricature, parody or pastiche; and the incidental inclusion of copyright material.
7. USER CONTENT
7.1 User Content on the Site includes (but is not necessarily limited to):
7.1.1 advertisements and promotions for Brands and Charities;
7.1.2 details of Benefits;
7.1.3 options in respect of Donations.
7.2 An Account is required if you wish to submit User Content. Please refer to clause 4 for more information.
7.3 You agree that you will be solely responsible for your User Content. Specifically, you agree, represent and warrant that you have the right to submit the User Content and that all such User Content will comply with POGO’s Acceptable Usage Policy, detailed below in clause 14.
7.4 You agree that you will be liable to POGO and will, to the fullest extent permissible by law, indemnify POGO for any breach of the warranties given by you under clause 8.3. You will be responsible for any loss or damage suffered by POGO as a result of such breach.
7.5 You (or your licensors, as appropriate) retain ownership of your User Content and all intellectual property rights subsisting therein. When you submit User Content you grant POGO an unconditional, non-exclusive, fully transferrable, royalty-free, perpetual, irrevocable, worldwide licence to use, store, archive, syndicate, publish, transmit, adapt, edit, reproduce, distribute, prepare derivative works from, display, perform and sub-licence your User Content for the purposes of operating and promoting the Site. In addition, you also grant Other Users the right to copy and quote your User Content within the Site.
7.6 If you wish to remove User Content from the Site, the User Content in question will be deleted. Please note, however, that caching or references to your User Content may not be made immediately unavailable (or may not be made unavailable at all where they are outside of POGO’s reasonable control).
7.7 POGO may reject, reclassify, or remove any User Content from the Site where, in POGO’s sole opinion, it violates POGO’s Acceptable Usage Policy, or If POGO receive a complaint from a third party and determine that the User Content in question should be removed as a result.
8. LINKS TO POGO’S SITE
8.1 Users may link to any page of the Site provided that:
8.1.1 you do so in a fair and legal manner;
8.1.2 you do not do so in a manner that suggests any form of association, endorsement or approval on POGO’s part where none exists;
8.1.3 you do not use any logos or trade marks displayed on the Site without POGO’s express written permission; and
8.1.4 you do not do so in a way that is calculated to damage POGO’s reputation or to take unfair advantage of it.
8.2 Framing or embedding of the Site on other websites is not permitted without POGO’s express written permission. Please contact POGO at [email@example.com] for further information.
8.3 You may not link to the Site from any other site the main content of which contains material that:
8.3.1 is obscene, deliberately offensive, hateful or otherwise inflammatory;
8.3.2 promotes violence;
8.3.3 is sexually explicit;
8.3.4 promotes or assists in any form of unlawful activity;
8.3.5 discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;
8.3.6 is intended or is otherwise likely to defame, threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
8.3.7 is calculated or is otherwise likely to deceive another person;
8.3.8 is intended or is otherwise likely to infringe (or to threaten to infringe) another person’s privacy;
8.3.9 misleadingly impersonates any person or otherwise misrepresents the identity or affiliation of a particular person in a way that is calculated to deceive;
8.3.10 implies any form of affiliation with POGO where none exists;
8.3.11 infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, trade marks and database rights) of any other party; or
8.3.12 is made in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
8.4 The content restrictions in clause 8.3 do not apply to content submitted to sites by other users provided that the primary purpose of the site accords with the provisions of clause 8.3. You are not, for example, prohibited from posting links on general-purpose social networking sites merely because another user may post such content. You are, however, prohibited from posting links on websites which focus on or encourage the submission of such content from users.
9. LINKS TO OTHER SITES
Links to other sites may be included on the Site. Unless expressly stated, these sites are not under POGO’s control. POGO neither assumes nor accepts responsibility or liability for the content of third party sites. The inclusion of a link to another site on the Site is for information only and does not imply any endorsement of the sites themselves or of those in control of them.
10.1 Nothing on the Site constitutes advice on which you should rely. It is provided for general information purposes only.
10.2 Insofar as is permitted by law, POGO make no representation, warranty, or guarantee that the Site will meet your requirements, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure. If, as a result of POGO’s failure to exercise reasonable care and skill, any digital content from the Site damages your device or other digital content belonging to you, you may be entitled to certain legal remedies. For more details concerning your rights and remedies as a consumer, please contact your local Citizens Advice Bureau or Trading Standards Office.
10.3 POGO makes reasonable efforts to ensure that the Content on the Site is complete, accurate, and up-to-date. POGO does not, however, make any representations, warranties or guarantees (whether express or implied) that the Content is complete, accurate, or up-to-date. Please note that this exception does not apply to information concerning products or services for sale through the Site.
10.4 POGO makes all reasonable efforts to ensure that Benefits earned by Donors on the Site are honoured and made available by the respective Brands. POGO does not, however, make any representations, warranties or guarantees (whether express or implied) that any such Benefits will be available, suitable, comply with relevant laws or with representations made on the Site or be fit for purpose.
11. POGO’S LIABILITY
11.1 To the fullest extent permissible by law:
11.1.1 POGO accepts no liability to any User for any loss or damage, whether foreseeable or otherwise, in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising out of or in connection with the use of (or inability to use) the Site or the use of or reliance upon any Content (including User Content) included on the Site;
11.1.2 POGO excludes all liability to any User in respect of Benefits, including but not limited to Benefits being unavailable, unsuitable, not complying the relevant laws or not complying with representations made on the Site, or not being fit for purpose; and
11.1.3 POGO excludes all representations, warranties, and guarantees (whether express or implied) that may apply to the Site or any Content included on the Site.
11.2 If you are a business User, POGO accept no liability for loss of profits, sales, business or revenue; loss of business opportunity, goodwill or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.
11.3 POGO exercises all reasonable skill and care to ensure that the Site is free from viruses and other malware. However, subject to clause 11.2, POGO accepts no liability for any loss or damage resulting from a virus or other malware, a distributed denial of service attack, or other harmful material or event that may adversely affect your hardware, software, data or other material that occurs as a result of your use of the Site (including the downloading of any Content from it) or any other site referred to on the Site.
11.4 POGO neither assumes nor accepts responsibility or liability arising out of any disruption or non-availability of the Site resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, natural events, acts of war, or legal restrictions and censorship.
11.5 Nothing in these Terms excludes or restricts POGO’s liability for fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be excluded or restricted by law. For full details of consumers’ legal rights, including those relating to digital content, please contact your local Citizens’ Advice Bureau or Trading Standards Office.
12. VIRUSES, MALWARE AND SECURITY
12.1 POGO exercises all reasonable skill and care to ensure that the Site is secure and free from viruses and other malware.
12.2 You are responsible for protecting your hardware, software, data and other material from viruses, malware, and other internet security risks.
12.3 You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via the Site.
12.4 You must not attempt to gain unauthorised access to any part of the Site, the server on which the Site is stored, or any other server, computer, or database connected to the Site.
12.5 You must not attack the Site by means of a denial of service attack, a distributed denial of service attack, or by any other means.
12.6 By breaching the provisions of clauses 13.3 to 13.5 you may be committing a criminal offence under the Computer Misuse Act 1990. Any and all such breaches will be reported to the relevant law enforcement authorities and POGO will cooperate fully with those authorities by disclosing your identity to them. Your right to use the Site will cease immediately in the event of such a breach.
13. ACCEPTABLE USAGE POLICY
13.1 You may only use the Site in a manner that is lawful and that complies with the provisions of this clause 14. Specifically:
13.1.1 you must ensure that you comply fully with any and all local, national or international laws and/or regulations;
13.1.2 you must not use the Site in any way, or for any purpose, that is unlawful or fraudulent;
13.1.3 you must not use the Site to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software, or data of any kind; and
13.1.4 you must not use the Site in any way, or for any purpose, that is intended to harm any person or persons in any way.
13.2 When submitting User Content (or communicating in any other way using the Site), you must not submit, communicate or otherwise do anything that:
13.2.1 is obscene, deliberately offensive, hateful or otherwise inflammatory;
13.2.2 promotes violence;
13.2.3 is sexually explicit;
13.2.4 promotes or assists in any form of unlawful activity;
13.2.5 discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation or age;
13.2.6 is intended or otherwise likely to defame, threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
13.2.7 is calculated or is otherwise likely to deceive;
13.2.8 is intended or otherwise likely to infringe (or threaten to infringe) another person’s right to privacy or otherwise uses their personal data in a way that you do not have a right to;
13.2.9 misleadingly impersonates any person or otherwise misrepresents your identity or affiliation in a way that is calculated to deceive;
13.2.10 implies any form of affiliation with POGO where none exists;
13.2.11 infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, patents, trade marks and database rights) of any other party; or
13.2.12 is in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
13.3 POGO reserves the right to suspend or terminate your access to the Site if you materially breach the provisions of this clause 13 or any of the other provisions of these Terms. Specifically, POGO may take one or more of the following actions:
13.3.1 suspend, whether temporarily or permanently, your Account and/or your right to access the Site;
13.3.2 remove any User Content submitted by you that violates this Acceptable Usage Policy;
13.3.3 issue you with a written warning;
13.3.4 take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;
13.3.5 take further legal action against you as appropriate;
13.3.6 disclose such information to law enforcement authorities as required or as POGO deem reasonably necessary; and/or
13.3.7 any other actions which POGO deem reasonably appropriate (and lawful).
13.4 POGO hereby excludes any and all liability arising out of any actions (including, but not limited to those set out above) that POGO may take in response to breaches of these Terms.
14. PRIVACY AND COOKIES
Use of the Site is also governed by POGO’s Cookie and Privacy Policies, available below. These policies are incorporated into these Terms by this reference.
15. CHANGES TO THESE TERMS
15.1 POGO may alter these Terms at any time. Any such changes will become binding on you upon your first use of the Site after the changes have been implemented. You are therefore advised to check this page from time to time.
15.2 In the event of any conflict between the current version of these Terms and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
16. CONTACTING US
To contact POGO, please email POGO at [firstname.lastname@example.org].
17. COMMUNICATIONS FROM US
17.1 If POGO has your contact details (if, for example, you have an Account) POGO may from time to time send you important notices by email. Such notices may relate to matters including, but not limited to, service changes, changes to these Terms, POGO’s Terms of Sale, and changes to your Account.
17.2 POGO will never send you marketing emails of any kind without your express consent. If you do give such consent, you may opt out at any time. Any and all marketing emails sent by POGO include an unsubscribe link. Email marketing options can also be changed by emailing [email@example.com]. If you opt out of receiving emails from us at any time, it may take up to 14 business days for POGO to comply with your request. During that time, you may continue to receive emails from POGO.
17.3 For questions or complaints about communications from POGO (including, but not limited to marketing emails), please contact POGO at [firstname.lastname@example.org].
18. DATA PROTECTION
19. LAW AND JURISDICTION
19.1 These Terms and Conditions, and the relationship between you and POGO (whether contractual or otherwise) shall be governed by, and construed in accordance with the law of England & Wales.
19.2 If you are a consumer, you will benefit from any mandatory provisions of the law in your country of residence. Nothing in clause 20.1 above takes away or reduces your rights as a consumer to rely on those provisions.
19.3 If you are a consumer, any dispute, controversy, proceedings or claim between you and POGO relating to these Terms and Conditions, or the relationship between you and POGO (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of England, Wales, Scotland, or Northern Ireland, as determined by your residency.
19.4 If you are a business, any disputes concerning these Terms and Conditions, the relationship between you and POGO, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the exclusive jurisdiction of the courts of England & Wales.
POGO Public 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.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 12.04.23. 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 donate via our iframe technology)
We may process: your name; address; email address; records of participation in our promotional campaigns; your marketing preferences, including any consents you may have given us (“identity and contact data”).
Once you donate via our Platform, 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: payment methods, time, place, charity donated to; amount and any other associated transaction information (“transaction 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 personal data is provided by you provide when you make a donation via our technology
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 this data is held and processed by Stripe, a third party payment provider
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:
- As required by us to conduct our business and pursue our legitimate interests, in particular:
- 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 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.
- As required by you and/or us on the basis of your consent
- to provide our services;
- to collect donations;
- to contact you with regards discounts and your donations;
- to process and fulfil requests in connection with our services such as provide a discount to you from one of our partner brands;
- to identify and authenticate you so you may access and use the Platform.
- 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 email@example.com
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 firstname.lastname@example.org
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
- 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 email@example.com 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”).
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:
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 firstname.lastname@example.org