Last updated: 24/10/19
SCOPE AND CONSENT
IMPORTANT INFORMATION AND WHO WE ARE
3.2. Data Controller
3.4. Third-Party Links
THE DATA WE COLLECT ABOUT YOU
4.1. 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 (anonymous data).
4.2. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
4.2.1. Identity Data
This includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
4.2.2. Contact Data
This includes billing address, delivery address, email address and telephone numbers.
4.2.3. Technical Data
This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this application.
4.2.4. Profile Data
This includes your username and password, history of transactions entered into by you, feedback and survey responses.
4.2.5. Usage Data
This includes information about how you use our application and services.
4.2.6. Marketing and Communications Data
This includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.4. We do not collect any Special 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, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4.5. 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 a loan). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
5.1. Direct Interactions
You may give us your Identity, Contact and Financial Data by filling in forms on the application or by corresponding with us by email. This includes Personal Data you provide when you:
5.1.1. apply for our products or services;
5.1.2. create an account on our application;
5.1.3. subscribe to our service or publications;
5.1.4. request marketing to be sent to you;
5.1.5. give us feedback or contact us.
5.2. Automated Technologies or Interactions
As you interact with our application, we will automatically collect Technical Data about your devices, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites and applications employing our cookies.
5.3. Third Parties or Publicly Available Sources.
We will receive Personal Data about you from various third parties and public sources including the following:
5.3.1. Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
5.3.2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services
5.3.3. Identity and Contact Data from data brokers or aggregators
5.3.4. Identity and Contact Data from publicly available sources
HOW WE USE YOUR PERSONAL DATA
6.1. 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:
6.1.1. Where we need to perform the contract we are about to enter into or have entered into with you.
6.1.2. 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.
6.1.3. Where we need to comply with a legal obligation.
6.2. 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
7.1. 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.
7.2. 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.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of Legitimate Interest|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(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 administer and protect our business and this application (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 use data analytics to improve our application, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our application 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
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.
7.4. Promotional Offers from Us
7.4.1. 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).
7.4.2. You will receive marketing communications from us if you have requested information from us or entered into an agreement with us and you have not opted out of receiving that marketing.
7.5. Third-Party Marketing
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
7.6. Opting Out
7.6.1. You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
7.6.2. 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 purchase, product/service experience or other transactions.
7.7. Change of Purpose
7.7.1. 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.
7.7.2. 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.
7.7.3. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
8.1. We may share your Personal Data with the parties set out below to provide our products and services to you
8.1.1. Internal Third Parties.
8.1.2. External Third Parties.
8.1.3. Specific third parties
8.2. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
8.3. In some cases we use suppliers located in various countries to collect, use, analyse, and otherwise process information on our behalf. We may also use subcontractors which provide services to us in connection with providing our Services to you. We put in place contractual safeguards for the protection of your personal data with such suppliers, including obligations for processing in line with applicable legal requirements.
8.4. We do not in any event sell or lease any of your personal information.
8.5. We may share your personal data based on a good faith belief that such disclosure is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the safety of any person.
8.6. We may use your personal data as evidence in litigation in which we are involved, to protect the rights or safety of any person or entity, to respond to a judicial process or valid government inquiry or as otherwise required by law.
9.1. We do not transfer your Personal Data outside the European Union.
10.1. 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.
10.2. 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.
11.1. How long will you use my Personal Data for?
11.1.1. 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. 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.
11.1.2. 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.
11.1.3. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax purposes.
11.1.4. In some circumstances you can ask us to delete your data (see below for further information).
11.1.5. In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
12.1. Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to the following:
12.1.1. Request access to your Personal Data
This is commonly known as a “data subject access request”. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
12.1.2. Request correction of your Personal Data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
12.1.3. Request erasure of your Personal Data
This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
12.1.4. Object to processing of your Personal Data
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
12.1.5. Request restriction of processing your Personal Data
This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
184.108.40.206. If you want us to establish the data’s accuracy.
220.127.116.11. Where our use of the data is unlawful but you do not want us to erase it.
18.104.22.168. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
22.214.171.124. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
12.1.6. Request transfer of your Personal Data.
You may request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
12.1.7. Right to withdraw consent
You may withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
12.2. If you wish to exercise any of the rights set out above, please contact us.
12.3. No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
12.4. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.5. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
13.1. Lawful Basis
13.1.1. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
13.1.2. Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
13.1.3. Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
13.2. Third Parties
13.2.1. Internal third parties
Other companies of the same group, which means our subsidiaries, affiliates, our holding company and its subsidiaries, acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.
13.2.2. External Third Parties
126.96.36.199. Service providers acting as processors who provide IT and system administration services.
188.8.131.52. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
184.108.40.206. The regulators and authorities acting as processors or joint controllers based in Greece, who require reporting of processing activities in certain circumstances.
14.2. If you have any questions or concerns regarding our policy, or if you believe our policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Privacy Department listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.
14.3. If you believe that Benefit is not processing your personal data in accordance with the requirements set out herein or applicable data protection laws, you can at any time lodge a complaint with the relevant supervisory authority.