Receipts Minder Privacy Notice

Effective
September, 2022

1. General

Receipts Minder Ltd. (“ReceiptsMinder”, “We”, ”Us”) as the developer of ReceiptsMinder digital platform, including mobile application (downloaded from Google App Store and the Apple App Store), web portal (the main domain of https://accounts.receiptsminder.com/ and its sub-domains), and the website (https://receiptsminder.com/) (collectively “Our Platform”), understands that your privacy is important to you and we take due care to the processing of your personal data.

It is important that you read this privacy notice (“Privacy Notice”) together with any other privacy notices or fair processing notices 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 other notices and privacy policies and is not intended to override them. Any changes to this Privacy Notice will apply when the changes are posted on Our Platform.

This Privacy Notice also helps us in complying with our applicable global data privacy laws, including without limitation the EU General Data Protection Regulation (“EU GDPR”) if you are located in the EEA, and the UK General Data Protection Regulation (the “UK GDPR”) if you are located in the UK, as applicable (each and collectively the “GDPR”, as applicable). We require the same from our partners (“Partners“), such as merchants providing electronic receipts (“Merchants“) and electronic Point of sale (POS) proivders (“ePOS Providers”).

Our Platform can be used by both private shoppers (“Shoppers”) and corporate customers and their representatives (“Business Customers”) by registering with us via our Platform or by concluding a separate contract with us. Additionally, our platform can be used by Partner representatives (“Business Clients”) to access services provided by ReceiptsMinder. Each Business Customer and Shopper (hereinafter referred also as “End User”) and Business Client has a contractual relationship with ReceiptsMinder.

2. Who We Are and Contacting Us

We are Receipts Minder Limited, a company incorporated in England and Wales with registered number 13204263 at Companies House and whose registered office is at 45 Thomas Brassey Close, Chester, England, CH2 3AE, United Kingdom.

If you have any questions about this Privacy Notice, please contact us by post (Postal Address: 45 Thomas Brassey Close, Chester, England, CH2 3AE, United Kingdom); or email (support@receiptsminder.com). Please ensure your query is clear, particularly if it is a request for information about  the personal data we hold about you. We hope that we can resolve any query or concern you raise about our use of your information.

The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

3. Data Security and Retention

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Usually that means we will keep your personal data for as long as you have a registered personal account with Us. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can terminate this account whenever you want to. When you delete your account, your personal data will be erased, deleted, destroyed, or otherwise disposed of.

4. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you.

Please see your rights below:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us support@receiptsminder.com.

5.  Our operations

ReceiptsMinder enables the provision and transmission of electronic receipts between our Partners and End Users. Our aim is to decrease the amount of paper receipts and to enable business related communication between our Partners and End Users based on electronic receipts. ReceiptsMinder enables, in particular, the following: Partners may provide electronic receipts to be forwarded by us to our End Users in accordance with this Privacy Notice and our terms and conditions.

Patterns may add to electronic receipts or otherwise send various marketing messages with our assistance to be displayed to End Users in accordance with the marketing legislation applicable from time to time. 

ReceiptsMinder may provide the Partners with anonymous statistical information about End Users who have transacted with the Partner in question, but always in such a format that it is not possible to identify individual End Users. ReceiptsMinder’s operation is based on that by means personal identifier (e.g. mobile phone number or email address) we can (i) reliably identify the electronic receipts of our End Users from the other electronic receipts provided by Partners using ReceiptsMinder, (ii) to store said receipts in our service, accessible to our End Users at our Platform, and (iii) to transmit the electronic receipts onwards in the manner agreed with the End User, unless the Partners who produced the receipt has not explicitly prohibited the transmission of its receipts to certain Partner Applications. Our End Users will see their electronic receipts transmitted by us in our service, as well as accessible to our End Users at our platform.

If an electronic receipt provided to us by a Partner does not concern our End Users, we will permanently delete the said receipt within five (5) business days after having received it without further processing. The receipts that concern our End Users are processed by us in accordance with our terms and conditions and this Privacy Notice.

Additionally, please note that although the electronic receipts produced by the Partners that relate to electronic receipts are based on ReceiptsMinder’s operations and the electronic receipts transmitted by us, the Partners are companies independent from ReceiptsMinder and always responsible for the legality of their own activities. The Partner is therefore always responsible for providing to you a receipt of your transaction. We therefore recommend that you carefully read the terms and conditions of the relevant Partner (inlcuding Merchant) and their privacy notices.

6 What kind of data do we process and where does it come from?

In order to enable ReceiiptsMinder’s operations, we process the following information about our End Users: mobile phone number, name, email address, contractual relationship information, log and other similar technical information regarding the use of the service/platform. For our Business Clients, we may also process information that is necessary for invoicing and fulfilling our contractual obligations. This information is obtained from our End Users and Business Clients, as well as from the log data of our service. 

With regard to purchase and payment transactions, we process for example the following information with regards to our End Users: the seller and its contact details, purchases with prices and taxes, date of receipt, filing identifier/reference of the receipt, last four digit of teh payment card used in connection with the purchase, and other information normally shown on the receipt. We receive this information from Merchants using ReceiptsMinder and electronic POS service providers.

Additionally, we also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated 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 a specific website 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.

7. For what purposes is the data used and what is the legal basis for processing?

Under Data Protection Laws, we must always have a lawful basis for using personal data.

The following lawful bases apply to our processing of your personal data:

• the processing is necessary for the performance of Services we provide pursuant to a contract we have entered into with the End User or Partner; or
• it is in our legitimate business interests to use it and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal obligation; or
• you have consented to our use of your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.

We have set out in the table below 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 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.

To the extent that direct marketing requires the express consent of End Users, we request the consent when the End User registers with ReceiptsMinder and the consent can be cancelled at any time. Please note, however, that withdrawal of consent does not affect the lawfulness of processing prior to withdrawal and does not prevent us from sending to our End Users information or communications that is necessary to End Users of ReceiptsMinder.

We process Partners’ data also for billing purposes. In this case, the processing is based on ensuring compliance with legal obligations.

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. 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.

8. To whom is your data transmitted or disclosed?

We transmit electronic receipts to our Partners (via our Platform) and, if our End Users so wish, to their personal communication tools (such as End User’s email address or direct download in our Platform). We will transmit promotional material (added to our Platfrom) by Business Clients to the End Users along with business logo and other material e.g. Business Name, address and other information present in receipt. 

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We process personal data also by resorting to services of third parties. For example, we use third party customer information systems to manage and communicate with our End Users. Correspondingly, we utilize third party data storage services to store and back up the data we process. Therefore, these third parties have access to the personal data we process. The said third parties act as processors of personal data and are not allowed to use the data for their own purposes. We have entered into data processing agreements with third parties to ensure that personal data are processed in accordance with data protection legislation.

Some of our service providers operate outside the EU/EEA area. We use EU Commission Model Clauses or Privacy Shield mechanism, if personal data is processed outside the EU/EEA area. For more information in this regard, please contact us if necessary (see section 2 of this Privacy Notice for contact details).

9. Cookie policy

Our Site may place and access certain first-party Cookies, web beacons or similar analytics technologies on your computer or device. First-party Cookies and web beacons are those placed directly by us and are used only by us. We use Cookies and web beacons to facilitate and improve your experience of Our Site and to provide and improve our Services. We have carefully chosen these Cookies and web beacons and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

We use the following first-party Cookies:

• Strictly necessary cookies. These are Cookies that are required for the operation of our Platform. They include, for example, Cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, 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 Site. 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 Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests.

You can find more information about the individual Cookies we use and the purposes for which we use them in the table below:

Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Platform may not function fully or as intended. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Platform more quickly and efficiently including, but not limited to, login and personalisation settings.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.