Last edition — 7thSeptember 2019
The website located at ecouponshares.com (“Website”) and the service is part of the eCoupon Shares Platform, which is operated by eCoupon Shares limited, a company operating under the UK laws, registered in England and Wales, registration No 11628958 ("us” “we” or “our"). We are the controller of your data for the purposes set out in this Policy and in our General Terms and Conditions
This Policy (together with our General Terms and Conditions and any other documents to which it refers) sets out the basis on which we process your personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting the Website and using the services set out in the Terms and Conditions you accept and consent to the practices described in this Policy.
We may change this Policy from time to time, and members are advised to review this Policy regularly to make sure that they read and understand the most current version of it.
Please note that use of our Website is not intended for or directed at persons under the age of 18. We do not knowingly collect personal information from anyone under the age of 18.
We collect and use personal data only to the extent necessary to provide our Website Services and to ensure their functionality. If the processing of personal data is necessary and such processing is not permitted by a legal basis, we generally obtain the consent of the data subject.
The legal basis to obtain the consent of the data subject for the processing of personal data is l Art. 6 para. 1 lit. GDPR.
If the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
eCoupon Shares, as the processor of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing
1. Data Controllers
1.1. eCoupon Shares limited is the controller of your data, in each case for the specific purposes set out below.
2. Information we collect from you
2.1.1. We may collect and process the following data about you. We routinely collect a range of general data and information each time we access our Platforms. This data is stored in the so-called log files of our system. We may record (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Platforms (so-called referrer), (4) the subwebsites which are accessed via an accessing system on our website, (5) the date and time of access to the Website, (6) the Internet Protocol address (IP address) and the Internet service provider of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.
For security purposes, in particular to trace the attack in the event of attacks on our Platforms, we store this data including the IP address for a period of seven days and then make the IP addresses anonymous or delete the data. The IP address is required to set up and during the connection to enable the contents of our Website to be delivered to you. The legal basis for the processing and subsequent storage of the IP address is a legitimate interest pursuant to Art. 6 para. 1 of GDPR. The legitimate interest with regard to the transmission of the IP address lies in the fact that this is necessary for the display of the contents of the respective Website; a display of the website is not possible without the transmission of the IP address. The legitimate interest in limited storage is our security interest.
When using this general data and information we do not draw any conclusions about you as a person. Rather, this information is required to (1) correctly deliver the contents of our Website, (2) optimize the contents of our Website and the advertising for them, (3) ensure the permanent functionality of our information technology systems and the technology of our Website, and (4) provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by eCoupon Shares both statistically and with the aim of increasing data protection and data security in our company in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the log files are stored separately from all personal data provided by a person concerned. The data will not be passed on to third parties.
2.1.2. Information you give us.You may give us information about you when using the Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide on registration, on your Account profile, in an order on our Website, when participating in discussion boards or other social media functions on our Website, when you enter a competition, promotion or survey, when you report a problem with our Website or other activities commonly carried out on our Website from time to time. The information you give us may include your name, age, address, e-mail address and phone number, financial and credit card information, personal description and interests, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, photographs, and any other data.
In connection with every use of the eCoupon Shares account, we automatically process the log-in data in order to prevent misuse or fraudulent use of our Services, to defend against attacks on our system and to ensure and verify the proper performance of the contractual Services at any time.
The legal basis for the storage and use of your personal data in connection with your eCoupon Shares account is the fulfilment of your contract with us, art. 6 par. 1 lit. b GDPR. If you provide certain profile details voluntarily, such as your full name, your consent is the legal basis, Art. 6 para. 1 lit. a GDPR.
We store your personal data for as long as this is necessary to provide the contractually agreed service. The personal data stored by you in your eCoupon Shares account are available to you for the duration of the contract and are stored by us for this duration. The personal data will be deleted if you do so in relation to individual data or the eCoupon Shares account as a whole, request us to do so accordingly or if the contract ends, i.e. if you or we terminate the contract. Please refer to our Terms of Use for more details.
2.1.3. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Alternatively, you can register with eCoupon Shares using one of your existing accounts with the following third parties and, if you are already registered, log in at a later time:
Facebook account ("Facebook Connect"). Facebook Connect is an offer of the social network "Facebook", which is operated by Facebook, Inc. based in 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter referred to as "Facebook"). Use of Facebook Connect is subject to Facebook's Privacy Policy and Terms of Use. When you use Facebook Connect, we gain access to the email that is stored on Facebook and other information that is available in your Facebook profile as public and publicly accessible.
The data transmitted to us by the respective provider will be processed by us in order to create or update a eCoupon Shares account for you and to make it available to you in accordance with Section 2.1.1.
Since we use the data to create a eCoupon Shares account, the legal basis for processing is the contract for an eCoupon Shares account pursuant to Art. 6 para. 1 lit. b GDPR, as described under 2.1.1. Your personal data will be stored with us for the purposes and duration described in Section 2.1.2.
2.1.4. Use of Referral services. If you make use of our Share & Earn referral Services, i.e. use our Platforms to make recommendations for eCoupon Shares or for products or online shops of our partner companies, we automatically process various data that is required to collect and process the rewards.
If you would like to make a recommendation, we will provide you with a personal recommendation link for this purpose, which contains a unique, pseudonymised user ID. The pseudonymous user ID is transmitted to us as soon as a friend or other recipient of the recommendation (hereinafter also referred to as "Referred Friend") follows your recommendation link and enables us to assign the activity of the Referred Friend, e.g. the execution of an order in the recommended shop, to your recommendation.
This is necessary to be able to credit your account with any bonus or you may have earned and to show you the history of your referrals in your eCoupon Shares account. If the person you refer makes the purchase via a telephone hotline or the shop of one of our partner companies, he can be asked for your e-mail address in this connection. This will be sent to us for the purpose of associating the bonus with your referral and crediting your eCoupon Shares account as described above.
The legal basis for the processing described above is in all cases art. 6 par. 1 lit. b GDPR, as the data processing is necessary to fulfil your contract with us. The data is stored for the duration described in Section 2.1.2
2.1.5. Rewards Payouts. If you want us to pay out any rewards or cashbacks you have earned, you can use the corresponding function in your account. Please refer to our Terms of Use for details. In this context, depending on your desired payment method, we will collect your bank account details or - in the case of payment via other payment service providers such as PayPal - the corresponding details of your account (e.g. your e-mail address used for PayPal) (hereinafter collectively also referred to as "Payment Details"). We transmit this data together with information on the rewards purchased to our bank or the respective payment service provider for payment processing. In these cases, the purpose is to enable the reward or cashback to be paid out to you. The legal basis is the fulfilment of your contract with us according to art. 6 par. 1 lit. b GDPR. The data is stored for the duration described in Section 2.1.2.
2.1.6. Accounting and Taxes. Within the framework of our statutory accounting obligations, we may also transmit payment data to our accounting offices and tax advisors. We also store the booking documents on which the payments are based, including the payment data contained therein, for a period of ten years in order to fulfil our statutory retention obligations pu, whereby the period begins at the end of the calendar year in which the booking document arose. The legal basis for such processing is Art. 6 para. 1 lit. c GDPR, the fulfilment of our legal obligations.
2.1.7. Orders requests. It is possible that our system does not record rewards or does not record them correctly for technical reasons or due to incorrect use. In this case you can make an order request via your Viucher Shares account. For processing we need certain personal data about you, such as your name, address and, if applicable, identification document, in order to be able to identify you and to prevent any improper or fraudulent use of our Services. Furthermore, in order to process the order request, we require personal data on the purchase or order for which you are claiming a reward in order to be able to check whether and by whom this transaction was actually carried out, i.e. whether it has not been cancelled and whether you fulfil the other reward conditions. To this end, we may also share the information you provide about the transaction with the partner company where the purchase was made. You can find out more about the reward conditions in our terms of use and in the additional conditions that are included in the respective reward offer.
The legal basis for this processing is the fulfilment of your contract with us in accordance with Art. 6 para. 1 letter b GDPR. We store this data until the order request is completed. This is the case if we can assume under the circumstances that there will be no further inquiries in a certain booking process and that claims will no longer be derived from this.
2.1.8. Processing of data of Referred Friends and customers of our Partner Companies. If you as the recipient of a recommendation made via our Services follow a recommendation link, we collect various data on your website usage behaviour through the use of cookies and similar technologies (for cookies, see the further explanations under Section 7). With the exception of the IP address, this is exclusively anonymous data, such as a shop and order ID as well as the price of the purchased product, which do not allow any conclusions to be drawn about your person. The purpose of the processing is to determine whether your usage behaviour is based on a recommendation, i.e. whether your purchase leads to a bonus entitlement with the recommender. The legal basis is a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The legitimate interest lies in the implementation of our business activities.
If you are the recipient of a referral made via our Services and make a purchase from one of our partner companies, you may be asked for your e-mail address in this connection if the referrer wishes to share with you or give it to you as a gift. This e-mail address is either collected by us or - if the purchase takes place via a telephone hotline or in a retail store - our company partner and transmitted to us. The e-mail address will be processed by us in order to credit the reward to your account or - if you do not yet have an eCoupon Shares account - to create a eCoupon Shares account in accordance with Section 2.1.2 and to credit the reward. The legal basis is therefore the conclusion or fulfilment of a contract in accordance with Art. 6 para. 1 lit. b GDPR.
IP addresses are stored by us for the purposes and duration described in Section 2.1.1 and then made anonymous. E-mail addresses are stored by us for the duration described in Section 2.1.2
3. Uses made of the information
3.1. We use the information held about you in the following ways:
3.1.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
3.1.2. all the information you provide on your Account profile will be displayed on your Account profile page;
3.1.3. to provide you with information about site activity, products or services we or feel may be of interest to you where you have indicated that you wish to receive this material. We may also contact you by electronic means (e-mail or SMS) with information about goods and services similar to those that you have already purchased, registered for or enquired about but we will always offer you an unsubscribe option when doing so..
3.1.4. to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.1.5. to improve our Website to ensure that content is presented in the most effective manner for you and your computer or other electronic device;
3.1.6. to allow you to participate in interactive features of our services;
3.1.7. as part of our efforts to keep our Website safe and secure;
3.1.8. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
3.1.9. to make suggestions and recommendations to you and other users of our Website about services that may interest you or them; and
3.2. You may unsubscribe from ecouponshares.com emails at any time by changing your Account profile settings or by following the unsubscribe link at the bottom of every ecouponshares.com email.
4. How we do not use your personal data
4.1. We shall not display any of your personal information such as your real name, e-mail address, full post code, mobile or landline phone number or IP-address, and we shall endeavour to keep the same strictly private and confidential. In any case when we ask for such information we make it clear that it is not for display without your consent.
4.2. We will not share your personal information with a third party for marketing purposes without your permission.
4.3. Your individual use of ecouponshares.com website and your interaction with us or other customers through these Website shall be kept strictly private (no responsibility is accepted for the actions of users of the Website or third parties).
5. Disclosure of your information
5.1. We may disclose your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries in the performance of our services to you.
5.2. We are required to give information to legal authorities if they have the proper authorization such as a search warrant or court order. We do our best to ensure that all information held relating to you is kept up-to-date, accurate and complete, but we also rely on you to notify us if your information requires updating or deleting.
6. Where we store your data
6.1. When you register to use ecouponshares.com, eCoupon Shares collects, stores and processes your data. After your data is collected we store your data and operate the services on the Website.
6.2. The data collected from you is therefore transferred to, and stored at, a destination of European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Policy.
6.3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6.4. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Cookies
7.1. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website and services provided. For detailed information on the cookies we use and the purposes for which we use them, and how to disable cookies using the privacy settings in your browser see our Cookie Notice
7.2. In the course of serving advertisements to these Website and you using some part of the Website, us or our third-party advertiseray place or recognize a unique cookie on your browser. Cookies are a normal part of Internet operations and are also used by ecouponshares.com to safely identify you each time you logon and use the Website and to keep your session active when you do not use the Website for some time. Any information that us, or third parties collect via cookies and marketing campaigns tracking software is anonymous.
8. Subject access
8.1. You have the right, subject to the payment of a small fee (currently £10), to request access to personal data that we may process about you. If you wish to exercise this right, you should:
8.1.1. put your request in writing;
8.1.2. include proof of your identity and address (e.g. a copy of your driving licence or passport, and a recent utility or credit card bill);
8.1.3. attach a cheque in the amount of £10 made payable to eCoupon Shares limited and
8.1.4. specify the personal data you want access to, including any account or reference numbers where applicable.
8.1.5.You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:
8.1.6. put your request in writing;
8.1.7. provide us with enough information to identify you (eg account number, name, registration details); and
8.1.8. specify the information that is incorrect and what it should be replaced with.
8.2. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:
8.2.1. put your request in writing (an email sent through our Contact Form with a header that identifies your user account and says 'Unsubscribe' is acceptable);
8.2.2. provide us with enough information to identify you (eg account number, name, registration details); and
8.2.3.i f your objection is not to direct marketing in general, but to direct marketing by a particular channel (eg email or telephone), please specify the channel you are objecting to.
8.3. Subject to certain exceptions, you also have the right to ask us to erase your personal data. If you wish to exercise this right, you should:
8.3.1. put your request in writing (an email sent through our Contact Form with a header that identifies your user account and says 'Right to be forgotten' is acceptable);
8.3.2. provide us with enough information to identify you (eg account number, name, registration details); and
8.3.3. specify the data that you wish to be erased.
9. Unsubscribe from email notifications
9.1. If you want to unsubscribe from receiving email notifications to your external mailbox, please use the link at the bottom of each email or go to Account Profile page and manage your e-mail settings. Our members have the following choices to modify or delete their information from our database:
9.1.1. Send an email to our friendly Customer Support team
9.1.2. Log in with your password and change/delete your profile
9.1.3. If you have questions or concerns, please use our Contact Form on ecouponshares.com web-site and our team will deal with your enquiry quickly, professionally and efficiently because we take privacy of our members seriously and are ready to address all the concerns they may have.
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