Bevvie Privacy Notice
Welcome to Bevvie
We are committed to respecting and protecting your privacy. This privacy notice sets out how we collect and use the personal data that you provide to us via this website, www.bevvieapp.com (our “Site“), and our mobile app, Bevvie (our “App“, and together with Site, and any other services we provide to you, our “Services“). It also tells you about your privacy rights and how certain laws may apply to you.
We have appointed a Data Protection Officer, and, therefore, if you have any queries about this notice or how we use your personal information, or any complaints, please contact our Data Protection Officer at firstname.lastname@example.org or by using our postal address listed in section 1 below.
1. About us
Our Services are operated by Bevvie (“Bevvie“, “us“, “we“, or “our“).
Bevvie is a limited company registered in England & Wales with company number 10763608, and with its registered office at 464 Edgware Road Suite 46, London, United Kingdom, W2 1AH. Bevvie is the data controller of any data you provide to us via our Services, and is registered with the UK Information Commissioner’s Office under number CSN3761185.
2. What personal data do we collect via the Services?
Our aim is to help you make new connections and enjoy exclusive events and deals. In order for us to do this, clearly we need some personal data about you and all of our other members.
‘Personal data’ means any data which can be associated with you as an individual, either directly or indirectly. We collect different information depending on how you use the Services and how you interact with us.
The personal data we collect via the Services may include:
- Basic Registration Information, such as your name, photo and date of birth (please see section 4a below for information on how and why we collect this information).
- Additional Identity Information, being information that you may choose to provide about yourself on your membership profile such as a short biography, the languages you speak, your country (or countries) of residence and your occupation.
- Contact data, such as your email and telephone details.
- Location data, such as the locations that you have checked in to and the dates and times that you have done so.
- Usage data, which includes information about how you use the Services (including any event bookings, reservations or other services we have provided to you and our conversations with you).
- Social media account information, if you create an account using Facebook, we will obtain information such as your name, Facebook ID, profile picture, network, gender, username, user ID, age range, language, country, friends list, followers and any other information you have agreed that the relevant platform can share.
- Payment and transaction information, including your transaction history with us (that is the Deals (as defined and referred to in our Terms and Conditions) you have purchased), and certain other information associated with your payments. This does not include your payment card details, which you provide direct to our payment processors, Stripe, and will be collected and processed in accordance with Stripe’s privacy policies (click here). We do not collect or store payment card details.
- Technical data, such as the device you are using to access our Services, your unique device ID, your internet protocol (IP), browser type and version, time zone and location (when you use the App), display settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
- Marketing and communications data, including any communications we may receive from you, for example if you participate in any surveys we run or if you communicate with us about the Services, and your preferences in receiving notifications, marketing and other communications from us.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). 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 App 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.
We do not ask you for ‘special categories’ of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or health information. However, you may choose to provide such information on your profile (which is entirely at your discretion; we encourage you not to provide such information) and, by doing so, you are explicitly consenting to our processing of that information and making it public to other members. Please do not share any information therefore that you are not comfortable making publicly available (to members or the general public, as we cannot control the activities of other users and therefore all information you share is done so at your own risk). We do not collect data about actual or alleged criminal offences.
3. How we collect personal data
Different personal data is collected in different ways.
- Personal data you provide to us
When you create an account to use our Services, you will provide us with your Basic Registration Information, any Additional Identity Information and your marketing and communications preferences.
You will provide us with your location data when you use the App and check in to one of our venues.
When you enter your payment card details via our Services, they are provided direct to our payment processors, Stripe and/or Checkout. We do not collect or store payment card details. You will also provide us with personal data when you correspond with us.
- Personal data provided by others
We may receive information about you from other members in the course of their use of the Services. For example, we may process your personal data if another member contacts us about you.
If you create your account using Facebook, then we receive the information you have agreed that platform can share with us, as set out in section 2 above.
- Personal data we collect as you use our Services
As you use the Services, we will collect your technical, usage and transaction data as described above.
Some of this data is collected using cookies, beacons and similar technologies. Cookies are files with small amount of data which are sent to your browser (or device) from our Services and stored on your device.
We use essential cookies to provide you with the Services via our App and the Site, namely IOS “User Defaults” and “local storage”. These are necessary for the Site and App to function. “User Defaults” will ensure that your default configuration and settings are loaded within the App, and “local storage” stores a token on your web browser, so that we know you are logged in to the Site and your session is live.
You can remove cookies from your computer through the settings on your browser, but be aware that this may impact your ability to make use of some features on our and other web sites. Management of cookie settings varies from one browser to another. The “Help” menu of your web browser will provide full instructions.
- Location data
We use GPS technology to determine your current location. The Services require your personal data for various features on the App and on our Site to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location data in your settings.
4. How and why we use personal data
We will only use your information where:
4.1. We need the information to fulfil contract(s) with you
We require certain personal data, for example the Basic Registration Data, in order to manage your account and provide the Services to you. For example:We will use your contact details so that we can communicate with you about the Services we provide, to facilitate providing our Services to you and, and to respond to any requests, queries, issues or concerns you may have.
- We will use your identity and log-in data create a public profile for you on our Services, in order to help you connect with other members. You will need this profile to use our Services.
- We will use your technical information to ensure that our Services display and function correctly on your device.
- We will use your location data
- We will use your identity, contact, log-in and usage data to customise our Services to you.
- We (and our service providers) will need your payment information to facilitate any payments you authorise. For further information about this, please see section 6 (‘How we share your data’) below.
4.2. We have a legitimate interest (reasonable business purpose) in doing so
We will use your information for our legitimate business reasons where our doing so will not unduly affect your rights.
We will use your identity, log-in, contact and usage information to keep our records up to date.
As part of our Services, we will invite you to exclusive events that we think you will be interested in and make you offers for Deals (please refer to section 4.2 of our Terms). We will also use your personal data to provide you with membership rewards and incentives.
We will use your technical, location and usage information to:
- provide and make improvements to our Services, system maintenance, support, reporting and hosting of data, and troubleshooting;
- ensure that our Services are secure;
- analyse how users interact with our Services; and
- develop new products and services.
We may also use any or all of the information above to administer and manage our business in general, to detect and prevent misuse of our Services (including fraud and unauthorised payments), and to enforce our Terms and Conditions or any other contract to which we may be a party. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.
4.3. You have given us your consent
As a member, we would like to send you marketing communications from time to time to let you know about our Services. We will do so only where you have recently made a purchase from us and we think you would be interested in a similar offer, or where we have obtained your consent to do so.
You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by emailing us at email@example.com.
If you have chosen to create an account with us using Facebook, we will have access to the information set out in section 2 (‘What personal data do we collect via the Services?’) above. If you would prefer that we do not have access to this personal data, you can create an account using only your mobile. Likewise, we will only share your personal data on Facebook, or any social media platform with your consent. We do not post on your social media accounts without your permission.
We will only ever store any ‘special categories’ of data when you have provided us with your explicit consent to this.
We will only ever use your location data if you have given us your consent to this. We use location data to provide you with Services that are of relevance to you (for example, we will use it to let you know which events are happening and / or Deals are on offer in your local area), and when you “check in” via the App to provide you with points, as set out in section 4.1 of our Terms and Conditions. Likewise, we may need your contact, identity, technical and/or usage information to respond to a question you have asked us.
4.4. We need to comply with a legal or regulatory obligation
In certain circumstances, we may need to retain or use your personal data to comply with regulations and/or the law (for example in the unlikely event that we become subject to a court order requiring us to disclose your personal data).
Our Services are not to be used by children, or indeed any person under the age of 21. Please do not provide us with any personal data relating to children.
6. How we share personal data
We will share your data:
6.1. With our trusted third party service providers, who help us to operate and provide the Services to you.
This means we will share your personal data:
- When you redeem a voucher awarded to you as part of our point system or when you purchase one of our Deals (as set out in section 4 of our Terms and Conditions), or if you provide your personal data in the course of any other offer we make you in the course of using our Services, we will share your details with the relevant redemption partner or supplier (our “Suppliers“). We will only disclose your information to Suppliers the extent necessary for the Service(s) you have requested. This will typically include your identity and contact information.
- We share certain information with our information technology providers, such as website and mailing list hosts.
- We may also share data with analysts, consultants and other professional advisors whom we retain for advice in respect of our business operations.
We will only disclose your data to third party service providers under terms of confidentiality, and they will only use your personal data for the purposes stated in this notice.
As noted above, we do not share your payment information with our payment processors – instead, you provide it to them direct. We use Stripe and Checkout. For information about how they use your personal data, please see their privacy notices at https://stripe.com/gb/privacy and https://www.checkout.com/legal/privacy-policy. The only exception to this is if we suspect that your account is being misused, in which case we may discuss certain aspects of your transaction history and/or identity details with our payment processors.
We will also share your information with other third parties and Suppliers, but only if you ask us to do so, for example, if we run a marketing campaign or survey pursuant to which you agree to provide your personal data to a third party (e.g. one of our advertising partners) in exchange for a benefit (e.g. a free drink from one of our Suppliers).
6.2. With other members of our Services
The Services are designed to enable you to connect with our members. You share information with other members via your profile when you make such information available via the Services. As we state above, please ensure that the information you make so available is information that you are happy being publicly viewed (please note that we cannot control what other users do with your information once it is disclosed).
6.3 If you choose to share it via social media
Where we provide the functionality, you may choose to share some of your information from our Services with your friends, followers or contacts on social media.
Your personal data may be disclosed or transferred to potential or actual buyers of, investors into or lenders to our business or any of our assets, or any of the advisors or representatives of the above. If so, we will ensure that appropriate confidentiality terms are in place.
We also collect, use and share, for example with advertisers and our Suppliers, Aggregated Data such as statistical or demographic data for any purpose. What we mean by this is, we will collect and combine your personal data with the data of others, and share it with third parties, in aggregated form (i.e. without names or otherwise in a manner which enables you or any other user to be directly or indirectly identified). For example, we may aggregate your usage data with the data of other members, in order to calculate the age range and gender of members who attend certain types of events on certain days. Such information can help our advertisers, Suppliers and other third parties identify trends, thereby enabling them to provide better and more relevant services which may interest you and other members.
If we combine or connect such 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. International transfer
Our Services are hosted on servers located in the United Kingdom.
In the event that we transfer personal data outside of the EU to a recipient in a third country in the absence of an adequacy decision by the European Commission, we take care to ensure that our data exports are compliant with data privacy law. We do this by relying on the Model Clauses and/or ensuring that the recipients of the data are certified under the EU-US Privacy Shield scheme. For further information, and/or to obtain copies of the relevant documents, please contact us at firstname.lastname@example.org.
8. Data security
The safety of your personal data is of paramount important to us, and we use various technical and organisational measures to ensure that your data is secure.
However no transmission of information via the Internet or electronic storage is ever completely secure. Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot guarantee the security of your data.
9. How long we keep personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
To obtain further information about how long we retain your personal data, please contact us at email@example.com.
10. Third party links
Our Service may contain links to third party sites whose information practices may be different than ours. Please consult all third party sites’ privacy notices, as we have no control over information that is submitted to, or collected by, third parties.
11. Your rights
You have the right to:
- require us to rectify the personal data we hold about you, where that data is incorrect;
- require that we restrict the processing of your personal information in certain circumstances;
- request access to the personal data that we hold about you;
- require that, in certain circumstances, we delete the personal information we hold about you;
- require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
- withdraw your consent to our using your data for marketing purposes at any time.
You also have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org.
To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
12. Changes to this notice or your data
We may amend or modify this privacy notice from time to time. We will post any revised notice on this site and on our app, and if the changes are significant, we will notify you by email.
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 was last updated on 18 April 2019.