Privacy Policy

Hello, welcome to the Slip Privacy Policy. At Slip, we are committed to keeping your personal information safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal information, what rights you have in relation to that information, who we share it with and everything else we think is important for you to be aware of.

Please make sure you check it carefully and if you don’t agree with it, then (although we hate to turn you away) you shouldn’t use ourPlatform or services. This is because by accessing our Platform or services, you confirm that you accept the way in which we process your personal information. This privacy policy forms part of our Terms, and capitalised words and phrases in it havethe same meaning as those in our Terms.

If you have any concerns, please feel free to contact us.

About Slip

We are Slip Technology Limited, a company incorporated and registered in England and Wales with company number13370492. Our registered office is at 120 New Cavendish Street, London W1W 6XX (referred to as Slip, we, our and us). We are the data controller for the purposes of the personal information processed in accordance with this Privacy Policy.

You can contact us regarding thisPrivacy Policy by web form here.

Contents of this Privacy Policy:

1.     About this Privacy Policy

2.     The personal information we collect, how we collect it, and why

3.     Our legal basis for processing personal information

4.     When do we share your personal information?

5.     Communications

6.     How long do we store your personal information?

7.     Security of your personal information

8.     Links

9.     Age restrictions

10.  Your rights and choices

11.  Contacting us

12.  Cookies

13.  General

In this Privacy Policy,unless the context requires a different interpretation:

a)     thesingular includes the plural and vice versa;

b)     referencesto sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses,schedules or appendices of this privacy policy;

c)     areference to a person includes firms, companies, government entities, trustsand partnerships;

d)     "including"is understood to mean "including without limitation";

e)     referenceto any statutory provision includes any modification or amendment of it;

f)      theheadings and sub-headings do not form part of this privacy policy.

1.    Aboutthis Privacy Policy

This Privacy Policy applies tothe personal information we collect about you through our Platform, bytelephone, by post, through our social media platforms, from third parties andwhen you otherwise communicate with us.

This Privacy Policy may changefrom time to time and, if it does, the up-to-date version will always beavailable on our Website. We will also tell you about any important changes toour Privacy Policy.

2.    The personalinformation we collect, how we collect it, and why

Personal information means any information about an individual from which that individual can be identified. The following shows information we process about you, and the purpose for which we process that information. There may be more than one reason for which we collect such information and we have only listed the main reasons. If you would like further information, please contact us.

Information

The main reasons we collect it

Information you provide to us

Customers: Customer account set up information, including your  name, email address, address, telephone number, gender, date of birth,  personal preferences, and any other requested information which Customers  provide

Your account information enables us to personally and uniquely  identify and communicate with you, both within the Platform, and externally  in emails, SMS messages and other forms of communication. It also makes you  visible and identifiable to us and by Clients. We also require this  information for account eligibility purposes and account maintenance  purposes.

Clients: Client account and profile set up information,  including business name, address, Client ID, contact information and other  account details which you provide to us.

This information enables us to set you up as a Client on our Platform  and communicate with you as envisaged by our Terms. We also require this  information for billing, account eligibility purposes and account maintenance  purposes.

Clients: Client review and feedback information.

We enable our Customers to browse Clients (including their  Promotional Offers) and we may provide different forms of feedback based on  their experiences with them.

Clients: Information provided during Client Checks

We may check our Clients to ensure they are suitable for our  Platform. We may use third party providers to carry out Checks, who may in  turn provide us with any documents (such as ID documents) which you provide  to them.

Your preferences for receiving communications and notifications

We store your preferences so we know exactly how to communicate with  you (e.g. for marketing or sending service communications), and in some  cases, how not to communicate with you.

Information we collect automatically

Account status

We store information about your account with us and interactions with  our service, including where Customers have an unregistered account, or a  full Customer Account.

User number

When a User signs up, we generate this as a mechanism to identify them  across our technical systems, and to link that Customer with their product  preferences, billing records, service interaction analytics and customer  service history.  

Your interactions with our service

 When you interact with our Platform, for example when a Customer gets  a Digital Receipt, or when a Client publishes a Promotional Offer, we record  and track this information for our ongoing operations and to analyse how our  Users enjoy our service so that we can continue to develop it.

Payment information (e.g. records of transactions)

Once applicable, we will record payment and transaction data to keep  financial and security records for our business and to comply with our legal  obligations to retain financial and transaction information.

IP address

This enables us to uniquely identify you and to distinguish you from  other Users. In turn, it enables us to deliver you a more personalised  service (e.g. more personalised Platform content).

Records of competitions, promotions, rewards and prizes

Whenever we hold competitions and/or give away rewards or prizes,  whether as part of Promotional Offers or otherwise, we keep an internal  record of how they have been distributed. We collect data around  competitions, how Users interact with them, and we use that data to improve  the way we hold competitions and give away rewards or prizes in future.

Information we collect from other sources

Social media information

As part of the sign-up process, we may import some of the information  you have disclosed to your social media pages, such as Facebook or Google (if  you choose to connect to Slip via a social network). Equally, certain parts  of our service enable you to share our content or information by email, text  (SMS) message or other social applications.

In respect of all the aboveinformation, our overarching purpose is to enable us to generate a trusted,secure portal for making receipts paperless. We want all of our Users’information to be secure, but also visible to us so that we can provide thempersonalised customer service and a customised User experience.

3.    Our legalbasis for processing personal information

We only ever use your informationin line with applicable data protection laws – in particular, the EU GeneralData Protection Regulation (GDPR)and the UK Data Protection Act 2018 (DPA 2018) and together the DataProtection Legislation. In short, this means we only use it where we have alegal basis to do so. Under the Data Protection Legislation, these are thegeneral legal bases for which we process your personal information, as detailedin the table above:

·      Consent– you have given us consent to process your personal information for a specificpurpose that we have told you about.

·      Performance of our contract – processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

·      Legitimate interests – processing your personal information is necessary for our legitimate interests or those of a third party, provided those interests arenot outweighed by your rights and interests (including where processing is required to comply with or enforce a legal obligation, or to exercise or defend our legal rights).

4.    Whendo we share your personal information?

We may disclose your informationfor certain purposes and to third parties, as described below:

·      Slip staffand our group of companies: we share your information with our staff(including employees, consultants, agents and advisors) and within the Slip groupof companies as required for: providing you with access to our servicesaccording to our agreement, data storage and processing, providing customersupport, making internal choices around business improvements, contentdevelopment, and for the other purposes set out in this Privacy Policy.

·      Clients: Where a Customer has previously opted in to share their personal informationwith a particular Client, directly with that Client, then the Customer’sTransaction data generated on Slip may then, in accordance with the agreedterms between the Client and the Customer, then be shared with the Client bySlip. This is always subject to the Customer granting their consent to theClient for this information to be shared.

·      Third Party Providers: We use certain companies, agents or contractors (Third Party Providers) to perform services on our behalf or to help deliver our services to you. In particular, we contract with Third Party Providers, for example to provide advertising, marketing, communications, identity checking, infrastructure and IT services, to personalise and enhance our services, to provide customer service, to collect debts, to analyse and action data (including data about our Users’ interactions with our Platform),and to process and administer consumer surveys. In the course of providing such services, these Third Party Providers may have access to your personal information. We do not authorise them to use or disclose your personal information except in connection with providing their services to us.

·      Promotions with our partners: We may offer joint promotions, schemes or incentives with our selected partners (including Clients where applicable) that, in order for you to participate, will require us to share your information with the relevant partner. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the relevant incentive. Please note that our partners are responsible for their own privacy and data protection methods and if applicable you should refer to their relevant privacy policy.

·      To protect legitimate interests: There are certain circumstances where Slip and our Third Party Providers may disclose and/or make use of your information where a disclosure would be necessary to: (a) satisfy any applicable law, regulation, legal process, or other legal or governmental request or requirement, (b) enforce applicable terms of use, including investigation of any actual or alleged breaches, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Slip, its Users or the public, as required or permitted by law.

·      Transfers of our business: In connection with any corporate reorganisation, restructuring, investment, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to comply with our requirements as set out in this PrivacyPolicy relating to your personal information.

5.    Communications

This section is to explain how wewill ensure that you only receive communications that you wish to receive.

Marketing communications:

We want to ensure that you areinformed and aware of the best services and promotions that we can offer you.By consenting to receive additional communications (by mail, telephone,text/picture/video message or email) from us and any named third parties thatfeature at the point of obtaining consent in respect of such information, wewill process your personal information in accordance with this Privacy Policy.

You can change your marketing preferences andunsubscribe at any time by accessing the settings within our Platform oremailing us. If you choose notto receive this information we will be unable to keep you informed of newservices and promotions of ours, or the Slip group of companies, that mayinterest you.

Whatever you choose, you’ll still receive otherimportant information, for example service updates, as described below.

Service communications:

As detailed in the table at section 2, we may sendyou communications such as those which relate to any service updates (e.g. newproduct features, service availability) or provide customer satisfactionsurveys. We consider that we can lawfully send these communications to you aswe have a legitimate interest to do so, namely to effectively provide you withthe best service we can and to grow our business.

6.    How long do we store your personal information?

Unless a longer retention periodis required or permitted by law, we will only hold your personal information onour systems for the period necessary to fulfil the purposes outlined in this PrivacyPolicy or until you request that the Data be deleted. Even if we delete your personalinformation, it may persist on backup or archival media for legal, tax orregulatory purposes.

In accordance with this PrivacyPolicy, you have the right to request that we delete your personal information,except where we are legally permitted or required to maintain certain personal information.For example:

·      We are legally required to retain financial andtransaction data for a minimum period of 7 years for tax, audit and accountingpurposes. This includes keeping a record of the amount of each transaction,what it related to, and who we transacted with.  

·      We will retain Digital Receipt records within a User’s account at least so long as the User is active and their account has not been deleted.

·      If there is an unresolved issue relating to aCustomer Account, for example relating to an issue with Digital Receipts or anunresolved dispute, then we will retain your personal information until theissue is resolved.

·      There may be other situations where we havelegitimate business interests to retain personal information, such as toprevent fraud or protect security of our other Users.

Any Third Party Providers that weengage will keep your personal information stored on their systems for as longas is necessary to provide the relevant services to you or us. If we end ourrelationship with any third party providers, we will take reasonable steps toensure that they securely delete or return your personal information to us.

We may retain personal information about you forstatistical purposes. Where information is retained for statistical purposes itwill always be anonymised, meaning that you will not be identifiable from that information.

7.    Security of your personal information

We are committed to securing and protecting your personal information, and we make sure to implement appropriate technical and organisational measures to help protect the security of your personal information.We may adopt various policies including anonymisation, pseudonymisation, encryption, password restricted access, and retention policies to guard against unauthorised access and unnecessary retention of personal information in our systems.

The information that we collect from you may be transferred to, and stored at, a destination outside of theEuropean Economic Area (EEA). When we transfer and store your personal information outside of the EEA we will take steps to ensure that the information is transferred in accordance with this Privacy Policy and applicable data protection laws. In particular, we will ensure that appropriate contractual, technical, and organisational measures are in place with any parties outside the EEA such as the Standard Contractual Clauses approved by the EU Commission.

Unfortunately, the transmissionof your personal information via the internet is not completely secure andalthough we do our best to protect your personal information, we cannotguarantee the security of your information transmitted to us over the internetand you acknowledge that any transmission is at your own risk.

8.    Links

Our Platform may, from time totime, contain links to websites operated by third parties, which will usuallybe those of Clients or our commercial partners. This Privacy Policy onlyapplies to the personal information that we collect from you and we cannot beresponsible for personal information collected and stored by third parties. Ifyou click on a link, please understand that the relevant third party websiteshave their own terms and conditions and privacy policies, and we do not acceptany responsibility for the content of those third party websites or third partyterms and conditions or policies. Please check these policies before you submitany personal information to these websites.

9.    Age restrictions

You must be 16 years of age orolder to use the Platform. We do not knowingly collect personal informationfrom individuals under 16 years of age. If you are under that age limit, thenplease do not use Slip or provide any personal information to us. If you areunder 18 years of age, then you will be required to have consent of your parentor guardian to access the Platform and we will only process the basicinformation which we require from you for so that you can use our Platform.

If you are a parent or legal guardian of a child under the applicable age limit or accessing the Platform without consent, and you become aware that your child has provided his/her personal information to us, please contact us. If we learn that we have collected personal information of an individual under the age of 16, then we will take all reasonable steps to delete that information from our systems, and if required, delete the relevant User account.

10.  Your rights and choices

This section explains that youhave a number of rights in relation to your personal information.

Under the GDPR and the UK DataProtection Act 2018, as a User of our Platform, you are entitled to certainrights. There are circumstances in which your rights may not apply. You havethe right to request that we:

·               provide you with acopy of the information we hold about you;

·               update any of yourpersonal information if it is inaccurate or out of date;

·               delete the personal informationwe hold about you - if we are providing services to you and you ask us todelete personal information we hold about you then we may be unable to continueproviding those services to you;

·               restrict the way inwhich we process your personal information;

·               stop processing yourdata if you have valid objections to such processing; and

·               transfer yourpersonal information to a third party.

For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

As explained in section 4, even if you consented to the processing of your personal information for marketing purposes (by ticking the relevant box or by requesting information about services for example), you have the right to ask us to stop processing your personal information for such purposes.You can exercise this right at any time by contacting us or adjusting your privacy and notification settings within the Platform. Please note that we reserve the right to charge a fee for responding to requests where we reasonably determine that they are manifestly unfounded or onerous or being made in bad faith.

11.  Contacting us

If you have any questions or concerns about how we handle your personal information, please contact us here.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

12.  Cookies

We may use cookies on our Platform which help us monitor use of the Platform, and in turn improve it based on how our Users interact with it. You can choose to accept or turn off cookies within your browser settings.

13.  General

You may not transfer any of yourrights under this Privacy Policy to any other person. We may transfer ourrights under this privacy policy where we reasonably believe your rights willnot be affected.

If any court or competentauthority finds that any provision of this Privacy Policy (or part of anyprovision) is invalid, illegal or unenforceable, that provision orpart-provision will, to the extent required, be deemed to be deleted, and thevalidity and enforceability of the other provisions of this Privacy Policy willnot be affected.

Unless otherwise agreed, nodelay, act or omission by a party in exercising any right or remedy will be deemeda waiver of that, or any other, right or remedy.

This Privacy Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.