Finders Keepers Club Ltd - Updated 7th July 2022
Introduction
Finders Keepers Club Ltd is a is an online retailer providing high quality brands at special prices only for their registered Members.
Finders Keepers Club Ltd and its entities (“we”, “us”, or “our”) understand that your privacy is important to you and that you care about how your personal data is used and shared by the Finders Keepers Club Ltd. Finders Keepers Club Ltd is committed to respecting and protecting your privacy. This Privacy Policy (the “Policy”) provides you with an overview of how we collect, store and use any personal data that you provide to us or that we collect from third parties.
Please take the time to read this Policy, which contains important information about the way in which we process personal data.
We are a limited liability company registered at: 3 Goldsmith Avenue, London, W3 6HR.
Our data protection officer can be contacted at Data Protection Officer, 3 Goldsmith Avenue, London, W3 6HR or by email at hello@finderskeepersclub.co.uk:
Who this policy applies to:
This policy applies to:
- Visitors to our website;
- All Finders Keepers Club Members and prospective or lapsed Members;
- Our clients and prospective clients;
- People who contact us with enquiries;
- Our suppliers and employees of suppliers.
Depending on our relationship, we will collect and use your information in different ways. What this policy contains: This privacy policy describes the following important topics relating to your information.
Your rights to object: You have various rights in respect of our use of your personal information as set out in section 8. Two of the fundamental rights to be aware of are that:
- you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
- you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.
1. How do we obtain your personal information?
1.1 You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, public websites and public agencies, which we refer to as "third party sources" or "suppliers" throughout this policy
1.2 You may give us personal information about yourself by using the online forms provided on our websites, engaging with us on projects, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive products, deliveries, information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.
2. Collection of your personal information and how we use it
Please go to the section(s) below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as 'personal information' throughout this policy.
2.1 Visitors to our website
What personal information we may collect about you We, or third parties on our behalf, may collect and use any of the following information about you for the reasons set out below:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us;
(vi) any updates to information provided to us;
(vii) personal information we collect about you or that we obtain from our third- party sources;
(viii) the following information created and recorded automatically when you visit our websites:
(a) Technical information. This includes: Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our websites, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and
(b) Information about your visit and your behaviour on our website (for example, the pages that you click on).This may include the website you visit before and after visiting our websites (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
(c) The purchases that you make via our online retail platform: www.finderskeepersclub.co.uk
(d) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to allow you to access, use and place orders via our websites;
(ii) to receive enquiries from you through our websites about our services;
(iii) for improvement and maintenance of our website and to provide technical support for our websites;
(iv) to ensure the security of our websites;
(v) to recognise you when you return to our websites, to store information about your preferences, and to allow us to customise the website according to your individual interests; and
(vi) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our websites, how they use our websites and to make our websites more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
Please see sections 2.8 and 2.9 for more details about how we use your personal information.
2.3 Attendees at any Finders Keepers Club Member events
(a) What personal information do we collect about you?
We, or third parties on our behalf, may collect and use any of the following information about you for the reasons set out below:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) video image for online conference and meetings (only if you choose to share your webcam);
(v) your telephone number;
(vi) your dietary and accessibility requirements;
(vii) health and safety information, including any accidents that you have at one of our events;
(b) How we use your personal information
We will collect, use and store the personal information listed above to administer your attendance at our events, and to deal with any enquiries or issues you have about our products and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. Please see sections 2.8 and 2.9 for more details about how we use your personal information.
2.5 Prospective customers and Members to whom we send marketing communications
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) social media profile details, as available publicly
(vi) information about your preferences.
(b) How we use your personal information
We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by telephone, email, post or social media channels) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters).
Please see sections 2.8 and 2.9 for more details about how we use your personal information. (c) Source of personal information. We may receive some of your personal information from third parties, such as marketing agencies.
2.6 People who contact us with enquiries
(a) What personal information do we collect about you?
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us; and
(vi) any updates to information provided to us.
(b) How we use your personal information
We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our products and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes.
Please see sections 2.8 and 2.9 for more details about how we use your personal information.
2.7 Our suppliers, and employees of our suppliers
What personal information do we collect about you?
We, or third parties on our behalf, may collect and use any of the following information about you for the reasons set out below:
(i) your name including your title;
(ii) work contact information (phone number, postal address, mailing address, email address);
(iv) your date of birth;
(v) information provided when you correspond with us;
(vi) any updates to information provided to us;
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to enable us to purchase and receive products and services from you or your employer (including supplier due diligence, payment and expense reporting and financial audits);
(ii) to assess your working capacity;
(iii) to deal with enquiries from you or your employer;
(v) for health and safety records and management; and
Please see sections 2.8 and 2.9 for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third party sources, such as your employer or your employer's company website. We may also collect this personal information from publicly-available sources, such as LinkedIn.
(d) Information we need to receive the services from you. Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer asks us to delete it, you may no longer be able to provide services to us.
2.8 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests to deal with your enquiries or requests;
(b) for internal Finders Keepers Club Ltd reporting, Finders Keepers Club Ltd administration, ensuring adequate insurance coverage for our operations, research and development, and to identify and implement operational efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
2.9 Further processing
Before using your personal information for any purposes which fall outside those set out in this section 2, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this section 2. Please contact us using the details in Section 13 if you want further information on the analysis we will undertake.
3. Legal basis for use of your personal information
3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to provide you with training services, a course or consultancy, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or
(b) our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes, anti-money laundering or compliance with HMRC requirements); or
(c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
(i) collect and use the information needed to run our events and courses;
(ii) analyse and advise on training and remote working needs
(iii) select appropriately skilled and qualified suppliers;
(iv) ensure a safe environment for our clients and suppliers;
(v) carry out marketing, market research and business development;
(vi) place, track and ensure fulfilment of orders with our suppliers; and
(vii) for internal administrative purposes.
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 13.
3.2 We may use your special categories of data (such as your dietary requirements when you attend a course) where you have provided your consent (which you may withdraw at any time after giving it, as described below).
3.3 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
3.4 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at hello@finderskeepersclub.co.uk and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide those services which require use of your special categories of data.
4. How and why we share your data?
4.1 We may sometimes contract with specially selected third parties to supply products and services to you on our behalf.
4.2 We will share your personal information with the following third parties or categories of third parties:
(a) our suppliers who support the delivery of products ordered on our website
(b) we may share anonymised and aggregated statistical information with our suppliers to demonstrate what interest there has been in any marketing campaigns we have assisted our suppliers in carrying out;
(c) our other service providers and sub-contractors, including suppliers of technical and support services, online conference and meeting providers, insurers, logistic providers, and cloud service providers;
(d) public agencies and the emergency services;
(e) companies that assist in our marketing, advertising and promotional activities;
(f) analytics and search engine providers that assist us in the improvement and optimisation of our website.
4.3 Any third parties set out in 4.4 above with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
4.4 We will also disclose your personal information to third parties:
(a) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(b) in order to enforce or apply our terms of use, our terms and conditions for suppliers or customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(c) to protect the rights, property, or safety of Finders Keepers Club Ltd, our staff, suppliers or customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
4.5 We may also disclose and use anonymised, aggregated reporting and statistics about users of our websites or our goods and services for the purpose of internal reporting or reporting to third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
4.6 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us, and we will stop doing so.
5. How long we store your personal information
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. If you would like further information on how long we retain your data then please contact us at hello@finderskeepersclub.co.uk
6. Where we may transfer your personal information
6.1 Your personal information may be used, stored and/or accessed by staff operating outside the EEA working for us, or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.
6.2 If we provide any personal information about you to any such non-EEA suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures will include the following:
(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
(b) in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them (or UK approved equivalent clauses).
6.3 Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us by email at hello@finderskeepersclub.co.uk at any time.
7. Risks and how we keep your personal information secure
7.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private.
7.2 For this reason, Finders Keepers Club Ltd is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
7.3 In the course of provision of your personal information to us, your personal information may be transferred to us over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
7.4 Where we have given you (or where you have chosen) a password which enables you to access an online account or content, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. Your Rights
8.1 You have the following rights in respect of our collection and use of your data under the GDPR. Your rights are as follows:
(a) The right of access to the personal data we hold about you. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").
(b) The right to rectification if any personal data we hold about you is inaccurate or incomplete. You have a right to request an update to any of your personal information which is out of date or incorrect.
(c) Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
(d) The right to restrict (i.e. prevent) the processing of your personal data. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
(e) Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
(f) Right to data portability: You have a right to ask us to provide your personal information to a third-party provider of services.
This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(g) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
8.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
8.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
8.4 We aim to give you strong controls on our use of your data for direct marketing purposes, including the ability to opt-out of receiving emails from us;
8.5 If you have a digital account with Finders Keepers Club Ltd you may be able to access our online portal to view and change some of your details. You will also be able to change your preferences regarding marketing messages. You can also access all personal information we hold on you by writing to us at: FAO: Data Protection Officer, Finders Keepers Club Ltd, 3 Goldsmith Avenue, London, W3 6HR You can also contact us by email at hello@finderskeepersclub.co.uk.
9. Marketing
9.1 We may collect and use your personal information for undertaking marketing, by email telephone, SMS and post.
9.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.
9.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
9.4 If you wish to stop receiving marketing communications, you can contact us by email at hello@finderskeepersclub.co.uk
10. Under 18
The products and services provided by Finders Keepers Club Ltd are intended for individuals over the age of 18 and our website and services are not directed at children and we do not knowingly collect any personal information from children.
If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as practicable.
Please contact us at hello@finderskeepersclub.co.uk if you are aware that we may have inadvertently collected personal information from a child.
11. Links to other websites
Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.
12. Our Use of Cookies
Our Finders Keepers Club Ltd Cookie policy is detailed below
Introduction
In this document you will find information on what cookies are used in this site and Finders Keepers Club Ltd microsites and how to reject or delete those cookies if you wish.
If you wish to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Information on deleting or controlling cookies as well as more general information about cookies is also available at www.aboutcookies.org
For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
What are Cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies by visiting: www.allaboutcookies.org or www.aboutcookies.org
How Finders Keepers Club Ltd Uses Cookies
Cookies allow Finders Keepers Club Ltd to recognise devices and track how our visitors use finderskeepersclub.co.uk. We use cookies that are essential for you to navigate finderskeepersclub.co.uk or provide you with basic website features. Data collected from some cookies helps us enhance the performance of finderskeepersclub.co.uk and offer you a better user experience.
There are several types of cookies that are used to keep track of information needed by a site user as they travel from page to page within a website.
Cookies on Finders Keepers Club Ltd Sites and Microsites
First-party cookies
The domain specified in the cookie relates to the cookie's owner (the "party"), who has set the cookie finderskeepersclub.co.uk cookies will have the finderskeepersclub.co.uk domain specified in a cookie. These are first-party cookies.
Third-party cookies and microsites
Cookies can be used to track internet activity after the user has left a website. These are normally facilitated by organisations external to the website being visited and are generally known as ‘third party’ cookies. They usually have a long lifetime with several months being quite common. They are 'harvested' and 'refreshed' whenever the user visits a page where the same or a similar cookie is being used.
finderskeepersclub.co.uk sets a number of cookies. These are used to analyse visitors' browsing of finderskeepersclub.co.uk for future improvements and to provide certain useful functions such as storing your login details.
A third-party cookie is set when you visit a site but the domain named in the cookie sent to your computer is not the same as the website.
Other Third Party processing activities
If you shorten our site URLs, for example on Twitter or Facebook, we may use services such as goo.gl, bit.ly, tinyurl.com and ow.ly to do so, and our site works with these to rebrand our URLs as a https://finderskeepersclub.co.uk/... link. Also, our website sometimes offers features that allow users to share links with social networks and our site may shorten that URL using one of these services. These services provide us with anonymised, aggregated statistics relating to the use of our shortened URL, for example by telling us how many times it has been clicked on. For more information on these services please see below:
- Google url shortener, goo.gl – Privacy policy
- Bitly Enterprise, bit.ly – Privacy policy
- TinyURL, tinyurl.com – Terms of use
- Ow.ly url shortener, ow.ly
Google Analytics
We currently use Google Analytics to measure and analyse visitor information related to our web site. For that purpose, your IP address, internet traffic data and data on your browser type and PC are collected using several cookies (_utma, _utmc, utmb, utmz):
- _utma is used by Google Analytics to identify first-time site ('unique') visitors vs. returning visitors. It expires after two years
- _utmc identifies unique visitors vs. returning visitors but expires when you close your browser.
- _utmb is used for general visitor tracking and expires after 30 minutes.
- _utmz tracks source visits (the origin of the visit). It expires after six months.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. For information on how to reject or delete this cookie. Please visit https://www.google.com/intl/en/privacypolicy.html for more information.
Microsites
Microsites are collections of webpages created as a discrete entity within a larger website. Microsite pages are usually related by content on a similar topic. They often have a different domain name from the parent website and content for microsites may be provided by specialist organisations.
finderskeepers.co.uk hosts microsites on our servers. Finders Keepers Club Ltd does not control dissemination of third party cookies.
Cookies Set By Third Party Sites
We sometimes need to embed media content from third party websites. For example, photos from flickr and video content from websites such as YouTube and Twitter. As a result, when you visit a page with content from sites like these, you may be presented with cookies from these websites. We do not control these so you should check the relevant third party website for more information.
Share Tools
If you share information on this site with friends through social networks e.g. Facebook or Twitter you may be sent cookies from these websites. We do not control these cookies so please check the relevant third party website for more information.
Rejecting cookies
Internet browsers normally accept cookies by default, but it is possible to set a browser to reject cookies. If this is done it is important not to exclude the benign and useful cookies. Choose an option that rejects all third party and long-lived cookies.
Policy review
For the avoidance of doubt all policies relating to GDPR and/or data protection (whether referred to on the Infonet, the Finders Keepers Club Ltd website or otherwise communicated to Finders Keepers Club Ltd staff, members or non- members) are not contractually binding on Finders Keepers Club Ltd and may be withdrawn or amended at any time. They will be under ongoing review and will be replaced with the latest versions accordingly.
13. Contacting us
13.1 If you have any questions about this Policy and how it affects you, please contact us by email at hello@finderskeepersclub.co.uk, or by post at Finders Keepers Club Ltd, 3 Goldsmith Avenue, London, W3 6HR;
13.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner's Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
14. Policy review
This Policy was last reviewed in March 2021. The content of the Policy may be reviewed and changed without prior notice. Any changes we make to our privacy policy in the future will be posted on this page.