Let's deal

Privacy Policy Let’s deal

Privacy Policy Let’s deal

Version 1.0

Let’s deal AB

May 2018

 

Introduction

Your privacy is important to us and therefore we take measures to protect it. This Privacy Policy explains how and why we process personal data and how we protect the privacy of our users. It also explains what rights you have when it comes to our processing of personal data and how you may exercise these rights.

It is our recommendation that you read this Privacy Policy in order to understand how and why we process personal data.

Data controller for the processing of personal data under this Privacy Policy is Let’s deal AB (“Let’s deal”). Let’s deal is a part of Schibsted Media Group.

 

Definitions

Personal Data – Any type of information that, directly or indirectly, can be linked to a natural person. Examples of such information or personally identifiable information are: your name, address, phone number, email address, payment card information, IP-address etc.

ProcessingProcessing of personal data means any operation or set of operations which is performed on personal data. Examples of processing is: collection, storage, disclosure by transmission, use, deletion etc.

Data ControllerThe natural or legal person who determines the purposes and means of the processing of personal data.

Data ProcessorAny natural or legal person processing personal data on behalf of the Data Controller.

Data Subject The identified or identifiable natural person which the personal data relates to.

Data Processor AgreementAn agreement governing the processing of the processor which sets out the subject-matter of the processing, the duration of the processing, the nature and purpose of the processing, the categories of data and categories of data subjects, the obligations and rights of the controller.

PartnerA legal or natural person contracted by us to sell goods or services via our platforms.

Legal BasisIn order for us to be permitted by law to process personal data, we must ensure that we have legal support for such processing. Such support is referred to legal basis.

 

Legal bases for Let’s deal’s  processing of personal data

Here at Let’s deal, we process your personal data in accordance with relevant law and we only process personal data when we have a legal basis for doing so. What legal basis we use may vary depending on what activity is concerned. If you want to learn more about the different legal bases for processing personal data, follow this link.

 

The legal bases that may be used by us at Let’s deal are the following:

  • ConsentThe data subject has given his or her consent to a certain processing activity.
  • Contractual obligation – The processing is necessary for the performance of a contract to which the data subject is party.
  • Legitimate interest – The processing is based on a balancing test between the interests of Let’s deal and the interests or fundamental rights and freedoms of the data subject.
  • Legal requirement – The processing is necessary for compliance with a legal obligation to which Let’s deal is subject.

 

 

Occasionally, we may have several legal bases for processing your personal data at the same time. For example, we could process your personal data after you have given your consent to it at the same time as we are legally obliged to process your personal data. This means that even if you withdraw your consent or another legal basis ceases to exist, Let’s deal may still continue to process your personal data if we have another legal basis for doing so.

 

Why Let’s deal need to process personal data

We want to continue offering deals to you in the best possible way even in the future. We also want to provide you with an optimal user experience when you use our services or buy something via Let’s deal. In order to do so, we need to process your personal data for a number of reasons, including the following:

 

  • i) To perform our contractual obligations

 

Let’s deal processes personal data and other information in order to provide our services, for example to allow you to purchase a service or to be able to deliver the purchased goods to you. We also process personal data to be able to provide a functional user account and to make the different features of such account function properly. The processing of personal data for this purpose is based on our contractual obligations with our customers or users.

 

  • ii) To provide personalised services
    Let’s deal wants to offer you recommendations and service adaptations based on your user behaviour in order to provide you with a personalised experience when using our services. For example, we arrange our deals based on the relevance these deals have to you and we also personalise our emails sent to you based on your preferences. To be able to conduct personalisation on these different matters, Let’s deal need to process personal data including your email, IP address, user ID, user behaviour and purchase data. The processing of personal data for this purpose is based on Let’s deal’s legitimate interest.

 

 

iii) To collect statistics to improve our services

It is business critical for us at Let’s deal to learn about what of parts of our services are used and what types of products or services that our users like the most. By learning this, we may improve our services so that they correspond to what our users want. The processing of personal data includes user behaviour and IP addresses. The processing of personal data for this purpose is based on Let’s deal’s legitimate interest.

 

When we or our partners suspect fraud or another criminal offence is being committed, we reserve the right to share with the competent authorities your personal data. This so the authorities may have access to whatever information they need to investigate the specific errand. The processing of personal data for that purpose is based on a legal obligation. There are also situations when our partners, for example Klarna, requests information about our customers in order to investigate attempts of fraud or other criminal behaviour. Upon such requests, we reserve the right to share with the requesting partner information that include your personal data to the extent necessary to conduct the investigation. This processing is based on Let’s deals legitimate interest.

 

  • iv) To track errors in our systems and to prevent misuse of our services

 

Let’s deal processes your personal data, including your user id, IP address and email, in order to track errors in our systems. The processing is carried out so that we may understand what users have been affected by a specific error. This processing activity is necessary for Let’s deal to be able to offer an adequate level of IT-security.

 

Let’s deal also processes personal data to prevent our services from being misused. Examples of misuse are attempts to log into other users’ accounts or to commit fraud, spamming or other forms or malicious behaviour.This processing of personal data for these purposes is based on Let’s deals legitimate interest.

 

When we, our partner or an authority suspect that there has been fraud or other criminal or inappropriate acts committed while using our services, we reserve the right to share personal data with authorities so that they may investigate the errand. The sharing of personal data for that reason is based on a legal obligation. There are also situations where a partner, such as Klarna, makes a request to us to share personal data with them so that they may investigate a certain event that may lead to prosecution. Upon such requests, Let’s deal reserves the right to share with partners the personal data necessary for the partner to investigate the relevant errand. When sharing personal data with partners for this purpose, we rely on legitimate interest as a legal basis.

 

  • v) To be able to give you relevant ads and marketing

 

Let’s deal wants ensure that you do not get irrelevant marketing. When we do not have ads on our own website, we collaborate with advertisers to provide marketing relevant for you on other websites. We share your user behaviour and interests with these advertisers in order for them to create and show you relevant ads when you enter other websites. As a main rule, Let’s deal is the data controller for the personal data that is collected by you when using our services. When it comes to the use of certain advertising platforms, such as Appnexus, Schibsted Sweden shall be considered as the data controller. If you want to learn more about Schibsted Sweden’s processing of personal data, click here.

 

To be able to your preferences with advertisers, we will ask for your consent. In case we do not have your consent, we will not share your personal data with any third party for the purposes of providing you with direkt marketing on other websites.

 

  • vi) To provide marketing via email/push messages

 

We may send out newsletters via email if you are an active user or an active customer to Let’s deal or if you have given your consent to receiving the newsletters. For active users and customers, the processing is based on the legitimate interest of Let’s deal. We may also send push notifications to you if you have allowed such in your settings on your device, thereby giving us your consent of sending out push notifications. If you do not want to receive marketing via email or via push notifications, you may withdraw your consent, change your settings on your device or opt out by mailing to [email protected].

 

vii) To measure the effectiveness of marketing on other websites

Let’s deal makes use of different services to measure the effectiveness of marketing made on other websites. This could be made by measuring how many of our users came from a specific ad or a specific campaign. Such measuring will require your consent. If you have given your consent, the personal data processed for these purposes are only processed until Let’s deal has collected the relevant statistics.

 

What categories of data does Let’s deal collect?

In order for us to provide the best possible services to you, we are dependant on processing different types of information, including your personal data. What personal data that is processed varies depending on what purpose the processing has. Comprehensively, we divide the personal data processed by us into three categories:

 

  • Information provided by you

 

When creating a user-account at Let’s deal, you will register your email address, your name and a password of your choice. The processing of this personal data is made to provide functionality to your user account and to deliver the agreed services related to such account. In short, to perform our contractual obligations under the agreement concluded with you upon creating an account. Schibsted Sweden is the data controller for the personal data linked to your user account as they provide the log-in solution and storage of data therein. If you want to read more about Schibsted Sweden’s processing of personal dala, click here.

Furthermore, Let’s deal processes personal data to fulfill our contractual obligations with you. This could include allowing you to pay for a product or to make delivery of an purchased product. An example of such personal data processed by Let’s deal is your name, email and delivery address, which we need in order to fulfill our part of the agreement with you as a customer, namely to deliver what you have purchased. The processing for these purposes is based on the contractual obligation of Let’s deal to perform its obligations with our customers. The personal data is processed until payment and delivery has been made, with an additional period of 36 months to be able to handle complaints and claims. The legal basis for the processing during the additional 36 months is legal requirement.

When you contact us, for example via our customer service, you may provide us with personal data, depending on what you contact us about. The processing of personal data for this purpose is supported by Let’s deal’s legitimate interest of being able to handle customer service errands. The processing could also be supported by our contractual obligation to fulfill the agreement between Let’s deal and you, depending on who you are, if you are a customer or solely an individual having general questions about Let’s deal. The personal data processed for these purposes is stored only for as long as it is necessary to complete the specific customer service errand.

When rating your deal or giving us feedback, you may provide us with certain information that could include personal data, depending on what you share with us. If you choose to share personal data with us via feedback functions, we will process such personal data based on Let’s deal’s legitimate interest. The personal data will only be stored until the feedback has been collected and anonymized.

On occasions, we may process your bank account number in order to provide you with refunds for any purchase made. Such occasion could be when a partner cannot fulfill their obligations under the purchase/delivery contract or when you are dissatisfied with the product/service. This processing activity is based on a contractual obligation or, in some cases, a legal requirement. We only process your bank account number until the relevant payment has been made. After that, the bank account number will cease to be processed by Let’s deal.

 

  • Information about your use of our services

 

When you use the services provided by Let’s deal, we will register information about what parts of our services you use and how you are using these. This type of information may include personal data and it can be divided into four different categories:

 

  • i) Information about your device

 

By using technical logs and other tools, we register information about the device you use, such as the device manufacturer, operating system and browser version. This information helps us adapt the way the content of Let’s deal is displayed according to your device and user situation. The processing of personal data for these purposes is based on Let’s deal’s legitimate interest. The personal data processed for these purposes is stored for 30 days from the point of you accessing Let’s deals services.

 

  • ii) Information about how our services are used

 

Here at Let’s deal, we collect information about how our users interact with our services in order to improve our services. In order to be able to improve our services based on what our users like, we need to process personal data such as IP addresses, user behaviour and user interests. With this personal data, we may learn what services and features of Let’s deal are most popular to our users.

Let’s deal registers what parts of our services users visit, when users visit them, how long certain pages are displayed, how users navigate our website, what functions of our website users interact with in order to create a basis for improving our services and in the prolongation offer more adequate services to our users.

The processing of the personal data for this purpose is based on Let’s deals legitimate interest and the personal data is stored for 14 months from the point of the data was collected.

You may opt out from being subject of this processing activity by changing your settings.

iii) Information about user location

We may register your geographical location based on your IP address and geoposition provided by your device only if you have given your consent to us doing so. If you have given us your consent to process your IP address and your geoposition, we process this type of data to offer you relevant deals and to adapt our services to your geographic position. The personal data for these purposes is stored and processed until you withdraw your consent.

 

  • iv) Local storage of data, including cookies and “similar technology”.

 

When you use Let’s deal’s services, we use cookies on your device for a number of purposes. For example, we use cookies to make our website function, to analyse what parts of our services you use and also, in case you have given your consent, to provide you with direct marketing via other websites.

For more information about how we use cookies, visit our Cookie Policy.

 

  • Information provided by others

 

On some occasions, we may receive personal data from others entities, meaning we do not acquire the personal data directly from you. This could be the case when authorities contact us with certain information or when our payment service providers share personal data with us that these service providers have collected themselves.

Personal data under this category may include information about your purchase such as payment method, purchased product, price etc. As the in-flow of personal data under this category may vary depending on who provide us with the information, we cannot provide a general legal basis or storage period for all the potential processing activities. If you have questions about what situations that may occur, please contact our customer service at [email protected]

Transmission of Personal Data

At some occasions, Let’s deal may share your personal data with third parties. Whenever sharing your personal data with third parties, we will be transparent about what we share and who we share the data with. Whenever we share your personal data with third parties, we will take precautionary measures to ensure that the personal data shared is not processed for additional purposes than those intended and that an adequate security level is provided by the party accessing the personal data.

 

Let’s deal may share personal data with third parties acting as data processors, meaning that they process the personal data on behalf of Let’s deal. Such data processors are subject to confidentiality and are not allowed to process personal data on behalf of Let’s deal for other purposes than to deliver the agreed services to Let’s deal. To ensure that Let’s deal’s data processors comply with relevant law and regulations, we conclude agreements with our data processors ensuring that the processing of personal data is done solely for the agreed purposes.

 

There are also instances when we share your personal data with third parties not acting as data processors. Upon sharing your personal data with such third parties, we will provide you with information about how and why we share the personal data.

 

How does Let’s deal ensure data minimisation?

Here at Let’s deal, we only process personal data that is adequate, relevant and limited to what is necessary for the purposes of their processing. We work actively and systematic to ensure that unnecessary personal data is excluded from the processing made by us at Let’s deal.

 

For how long do we process your personal data?

We will only process personal data for as long as it is necessary for the purposes for which the personal data is processed or for as long as it is required by law. Processing required by law could be keeping verifications used for accounting or keeping customer records for complaint and claims procedures linked to the purchased service or goods for as long as the law requires.

 

Let’s deal takes measures to ensure that your personal data is not stored longer than necessary.

 

Where do we process your personal data?

Our ambition is to only process your personal data within EU or EEA. Occasionally, when Let’s deal uses Data Processors who have their systems based outside EU, we conclude specific data processor agreements with these Processors to provide an adequate level of security when it comes to the processing of your personal data.

 

No matter where your personal data is processed, Let’s deal takes active measures to ensure that your personal data is not processed for other purposes than those intended.

 

How does Let’s deal protect your personal data?

Let’s deal takes technical and organisational measures to ensure an adequate protection of your personal data. Let’s deal have IT systems to ensure protection of your personal data and we have implemented routines within our organisation to ensure an adequate level of protection of personal data.

 

Let’s deal works actively to ensure that our employees only access your personal data in case it is necessary for them to perform a specific task to fulfill the purpose of why we process your personal data.

 

Your rights as Data Subject

As a logged-in user, you have the following rights:

  • To request access to any information Let’s deal processes about you. Such access shall be provided to in accordance with relevant law,
  • To request rectification of personal data that we process about you in accordance with relevant law,
  • To request deletion of the personal data we process about you
  • To request data portability in accordance with relevant law
  • To request restriction of the processing of personal data.

 

At any time, you may instruct Let’s deal not to process your personal data for the purposes of direct marketing.

 

After providing Let’s deal with your consent for a specific processing of personal data, you will be able to withdraw that consent at any time. The result of such withdrawal is that Let’s deal will cease to process your personal data for the purposes covered by your consent, if we do not have another legal basis for continuing to process your personal data.

 

Let’s deal may withhold personal data to the extent permitted or required by law. Thereby your rights as Data Subject may be limited by law.

 

When Let’s deal process your personal data based on our own legitimate interest, you may have the right to object to such processing. If you object to such processing, we must show why Let’s deal has a legitimate interest that trumps your interest, especially considering how intrusive our processing is to your rights and freedoms.

 

If you want to exercise any of these rights, please send a request to [email protected] Upon submitting such request, you will need to identify yourself by submitting a photo copy of either your driver’s license, passport, identity card or any other documentation that verifies your identity.

 

Implementing changes

Let’s deal will periodically update this Privacy Policy in order to make it correspond to our services provided. The latest version of this Privacy Policy is available on letsdeal.fi.

 

Contact details

If you have any questions regarding this Privacy Policy or about our processing of personal data, please contact our customer support here.

 

You may also contact the Supervisory Authority if you want to submit complaints about Let’s deal’s processing of personal data.

You may also contact our Data Protection Officer by filling in this form.