The Cheltenham Trust understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://thecheltenhamtrust.wearegifted.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About our Gift Voucher Scheme
Gifted forms part of our Site but is owned and operated The Hotel Marketing Group Ltd (HMG), a limited company registered in England under company number 07413674. Registered address: Midway House Herrick Way, Staverton Technology Park, Cheltenham GL51 6TQ.
2. What Does This Policy Cover?
3. Website Privacy Notice
For information on the following please review our Website Privacy Notice:
a) What is Personal data
b) Your Rights?
c) How to Access your Data
d) How to Control your Data
4. What Data Does Gifted Collect?
The Gifted platform collects the following personal and non-personal data:
- Email address;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5. How Does the Gifted Platform Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. With regards to Gifted this is because the data is necessary for our performance of a contract with you and/or because it is in our legitimate business interests to use it, for example to deliver the voucher to the recipient if different to you, the customer. Your personal data may be used for the following purposes:
- Providing and managing Customer Purchase to include delivery of voucher.
- Providing and managing your access to the Gifted platform;
- To facilitate gift voucher redemption. Your personal details are required in order for us enter into a contract with you.
- Personalising and tailoring the voucher for you, the Customer.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time).
- To process payments.
- To facilitate the administrative use of Gifted servers.
You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and applicable Privacy and Electronic Communications legislation.
6. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected, namely to discharge the contract with you and to keep in touch with you regarding our products and services if you have requested this.
7. Who Has Access to My Personal Data?
HMG collect the data set out under section 5 through the Gifted platform to facilitate the purchase. The Cheltenham Trust only use such data to facilitate the services purchased on a permission based system.
Sometimes contracts are entered into to supply certain products and services to ensure the Gifted platform works smoothly. These may include payment processing, postal or courier delivery, service facilitation and data hosting. In some cases, those third parties may require access to some or all of your personal data that we hold.
Only the payment processor has access to your full payment details, they are a certified PCI Level 1 Service Provider.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
8. How and Where Do You Store or Transfer My Personal Data?
The Cheltenham Trust and HMG may store or transfer some or all of your personal data in countries that are not part of the European Economic Area.
Payments are processed with Stripe Payments Europe Limited, an entity located in Ireland. In providing Stripe Services, Stripe Payments Europe transfers personal data to Stripe, Inc. in the US[RH1]. Stripe is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework. Stripe comply with applicable European laws on data protection and the transfer of personal data.
The remaining data captured through your gift voucher purchase by HMG is held on UK based servers, backed up in the EEA. HMG ensure all internet traffic is encrypted with the highest securities levels in operation regarding usage of the Gifted platform. For further information on The Cheltenham Trust please review their Website Privacy Notice.
9. How Can I Control My Personal Data?
In addition to your rights under the GDPR, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes.
10. How Do I Contact You?
To contact either The Cheltenham Trust OR HMG about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
The Cheltenham Trust
Email address: [email protected]
Telephone number: 01242 237431
Cheltenham Town Hall
Email address: [email protected]
Telephone number: 01242 682 050
Elmstone Business Park,
Extra Information from Gifted...
Internet Privacy and Cookies Policy
We do update this Policy from time to time so please do review this Policy regularly.
Information That We Collect
In running and maintaining our website we may collect and process the following data about you:
Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.
Information provided voluntarily by you. For example, when you register for information or make a purchase.
Information that you provide when you communicate with us by any means.
We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer's hard drive. Such information will not identify you personally; it is statistical data which does not identify any personal details whatsoever.
You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the 'settings' section of your browser. For more information please read the advice at AboutCookies.org.
Use of Your Information
We use the information that we collect from you to provide our services to you. In addition to this we may use the information for one or more of the following purposes:
To provide information to you that you request from us relating to our products or services.
To inform you of any changes to our website, services or goods and products.
If you have previously purchased goods or services from us we may provide to you details of similar goods or services, or other goods and services, that you may be interested in, if you opted in to receiving this type of communication at the point of your original purchase.
Storing Your Personal Data
In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transfer, storing and processing. We do our utmost to ensure that all reasonable steps are taken to make sure that your data is stored securely.
Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, sending such information is entirely at your own risk.
Disclosing Your Information
In the event that we sell any or all of our business to the buyer.
Where we are legally required by law to disclose your personal information.
To further fraud protection and reduce the risk of fraud.
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