RED SCARF LIMITED PRIVACY NOTICE (GDPR COMPLIANT)
Welcome to the Red Scarf Limited’s (company number 07909979) privacy notice.
Red Scarf Limited (collectively referred to as “Red Scarf”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or mobile application (the “Platforms”)(regardless of where you visit it from) and use our services and tells you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Red Scarf collects and processes your personal data through your use of the Platforms and engaging our services, including any data you may provide through the Platforms or by other means.
The Platforms not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing 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 our other notices and policies and is not intended to override them.
Red Scarf is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Red Scarf Limited
Name or title of DPO: Mr Jerry Chen, Digital Marketing Manager
Email address: email@example.com
Postal address: Kennington Business Centre 1-3 Brixton Road, London, England, SW9 6DE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us (our contact details are set out above) in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date as shown at the bottom of this privacy notice. Historic versions can be obtained by contacting us (our contact details are set out above).
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.
Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platforms, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Contact Data includes your email or a social media account of yours for registration.
• Identity Data includes your chosen username, gender, your chosen photograph and your location.
• Marketing and Communications Data includes your preferences regarding the marketing materials and information that you receive from us and our third parties and your communication preferences.
• Profile Data includes your interests, preferences (favourite brands and deals), feedback and survey responses.
• Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, heat map, operating system and platform and other technology on the devices you use to access our Platforms.
• Usage Data includes information about how you use our Platforms, products and services.
We also collect, use and share data such as statistical or demographic 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 and others’ Profile Data to calculate the percentage of users that have a specific preference. 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.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
· subscribe to our service or publications (for example, newsletter and push notifications);
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
· Technical Data analytics providers such as Google, Yandex and others based outside the EU;
· Contact Data from providers of technical services.
· Identity and Contact Data from data brokers or aggregators.
· Identity and Contact Data from publicly available sources such as Companies House and the Electoral
· Register based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (our contact details are set out above).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (our contact details are set out above) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To manage our relationship with you which will include:
(a) Notifying you about changes to
(b) Asking you to leave a review or
take a survey
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize
draw, competition or complete a
(d) Marketing and
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our
business and the Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for
running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant content and
advertisements to you and measure
or understand the effectiveness of
the advertising we serve to you
(e) Marketing and
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our
marketing, customer relationships
and experiences, we analyses
audience acquisition, behaviour and
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platforms updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and
recommendations to you about
goods or services that may be of
interest to you
Necessary for our legitimate interests (to
develop our products/services and grow our
We strive to provide you with choices regarding certain personal data uses, particularly around marketing
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any other company for
You can ask us or third parties to stop sending you marketing messages at any time by contacting us (our
contact details are set out above).
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us
as a result of a product/service experience.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Platforms when they are using them. This helps us to improve the way our Platforms work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Platforms. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Platforms, the pages you have visited and the links you have followed. We will use this information to make our Platforms and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (our contact details are set out above).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.