PRIVACY NOTICE

BACKGROUND:

RetailGreen Inc. 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 all of our ReceiptBox application users 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 applicable laws.

  1. Information About Us

  2. RetailGreen was founded in 2009 in San Francisco, USA, by a team of entrepreneurs committed to providing leading, innovative solutions to the retail industry.

    In a short period, RetailGreen has grown to become one of the world's leading providers of advanced technology for retail data analytics, serving Retailer Management, Mall Management and Retail Consumers.

    We provide safe, secure and private Value-Added Services that improve accuracy and governance through the provision of automated real-time sales data.

    We add value to retailers, shopping malls and consumers by leveraging sales data to provide analytics and actionable insights, enabling informed decision making and improved strategies.

    Today's consumers are smarter and more demanding than ever before. To be successful, retailers must be customer centric in their approach to marketing and merchandising.

    Customer centric companies should be looking to operate entirely in response to customer preferences. All available channels must be utilized to learn more about the needs and preferences of consumers, and to communicate with them more effectively


  3. What Does This Notice Cover?

  4. This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.


  5. What Is Personal Data?

  6. Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 5, below.


  7. What Are My Rights?

  8. Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
    2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
    8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask use for a copy of that personal data to re-use with another service or business in many cases.
    9. Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling.

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the relevant authority. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.


  9. What Personal Data Do You Collect and How?

  10. Depending upon your use of our App, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘sensitive’ personal data.

    Data Collected How [We] OR [I] Collect the Data
    Personal Contact information including email address, mobile number, name, date of birth, and gender. User entry in system screens.
    Data from third parties including personal contacts and personal information, which includes email address, mobile number, name, date of birth, and gender. From Google or Facebook if user registered or logged in using google or Facebook.
    User transactions information including income and expenses. User entry in system screens or through receipt scanning or systematic by eTenant system or Email My Receipt feature
    User device information including id, model, and operating system Automatic by system
    User location information including country and city Automatic by system


  11. How Do You Use My Personal Data?

  12. Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

    What [We] OR [I] Do What Data [We] OR [I] Use [Our] OR [My] Lawful Basis
    Session Management Email address and mobile number.
    Reporting and analyses Name, address, date of birth, and gender.
    Store income/expenses into personal receipt box accessible anywhere. Expenditures control and Spend Analysis User transactions.
    Multiple Devices Login Device ID, model, and operating system.
    Determining the default currency Country and city.

    With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and services. 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 Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

    We use our secured systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 11.

    We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

    If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

    In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.


  13. How Long Will You Keep My Personal Data?

  14. We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

    Type of Data How Long [We] OR [I] Keep It
    Personal information. Infinite.
    User transactions information.
    User device information.
    User location information.


  15. Is My Personal Data Protected?

  16. We will only store your personal data within the authorised area. Your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

    We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA”. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

    We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

    We as well share your data with external third parties, that are based outside of the EEA. The following safeguards are applied to such transfers:

    Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar levels of data protection to those in Europe. More information is available from the European Commission

    Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

    The security of your personal data is essential to us, and to protect your data, we limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;


  17. Do You Share My Personal Data?

  18. We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

    If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

    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.

    We may share your personal data with other companies in our group for necessary reasons. This includes subsidiaries, and our holding company and its subsidiaries.

    We may sometimes contract with the following third parties to supply products services.

    Recipient Activity Carried Out Sector Location


    If any of your personal data is shared with 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, as described above in Part 8.

    If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.


  19. How Can I Access My Personal Data?

  20. If you want to know what personal data, we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request in a timeline suitable with the complexity of your request. Normally, we aim to provide a complete response, including a copy of your personal data within that time


  21. How Do I Contact You?

  22. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of RetailGreen Inc):


  23. Changes to this Privacy Notice

  24. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be made available RetailGreen Website at e-RetailGreen.com . This Privacy Notice was last updated on 3rd July 2019.