VeeLoop Adult Privacy Policy

Welcome to our privacy notice. VeeLoop Ltd (”We”) are committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how VeeLoop Ltd collects and processes your personal data and the personal data of your children through your use of this website, including any data you or your child may provide directly through this website.
Our service enables children to fill up a basket online, send it to the parent for approval and to make payment. It is a safe and convenient way to enable young people to shop online independently.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 2018 (the Act) and the EU General Data Protection Regulation (GDPR), the data controller is VeeLoop Ltd of 30 Brunel Road, Manor Trading Estate, Benfleet, Essex, SS7 4PS. Our ICO registration number is ZA257303.
Our nominated Data Protection Officer (DPO) is Patricia Salume, one of our co-founders and you may contact our DPO to find out more about the way we treat and use personal data via email at hello@veeloop.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

WHO IS THE PRIVACY NOTICE FOR?
This privacy notice describes the way we treat and use personal data that we collect about any child or adult that uses our services. We believe that it is important that children also understand how we look after their personal data and what their privacy rights are so we have created a dedicated privacy notice for children.

NOTICE TO PARENTS AND GUARDIANS
You, as a parent or guardian of a child who has signed up to use our Services, is responsible for your child’s use of our services, including any purchases made.
As the parent or guardian of a child who has signed up to use our Services, you are giving us informed consent to:
  • Collect and use your child’s Personal Data in accordance with the terms of this privacy policy; (please be aware the only data we collect from your child is their email)
  • to contact your child by email as set under this privacy policy.

We feel passionately about creating an online culture where children can be open and honest. This is because we know that honesty is paramount for their safety and our ability to protect them. We also found through our market research, that one of the biggest frustrations children and teenagers felt when they used the internet, was that the companies they interacted with didn’t keep them in the loop about the activities they were carrying out online. That lack of transparency actually discouraged children from being honest, causing them in some instances to not be completely truthful, either about their age or whether they had permission from their parents to do something.
To build their trust, we want to show children that we take them seriously and that we understand and respect their wish to stay in the loop when they carry out online activities such as online shopping. For that reason, when a child checks out with VeeLoop for the fist time, we send them an email confirming their basket has been sent to the parent. This initial email is sent before parental consent is acquired but, as explained above, we believe this is fair and in the legitimate interest of the child (to keep them informed), and poses a low risk to the rights and freedom of the child.
When you sign up to VeeLoop and gives us consent to send emails to your child, we will only email them about their baskets and important service related updates and will not do anything else with their email. As mothers ourselves, we appreciate that children are more susceptible to suggestions and that they are more vulnerable than adults so we have a No Marketing to Children policy. We do not share any child data with any third party, including the retailers that they have purchased from, for any purpose.

WHAT INFORMATION DO WE ASK CHILDREN FOR?
When a child checks out with VeeLoop through one of our Retailer partner websites, this is what they see:

veeloop child registration form

The personal information we ask your child to provide us with are:
  • The child’s email address: so VeeLoop can send them an email confirmation of the basket sent to the parent
  • The parent’s email address: so we can send the parent an email notification about the basket awaiting their approval
  • A message from the child to the parent – the child may choose to add a message to the parent like "mum can I please have this pair of jeans"
  • A tick-box to confirm that the child understands our terms and privacy notices – these are written in simple language for the child to easily understand.

We do not share any child data with any third parties including the retailers they are attempting to purchase from.

WHAT OTHER INFORMATION DO WE COLLECT AND USE?
We will collect and process the following data about you:
  • Information you give us about you or your child. This is information about you or your child that you give us by filling in forms on our website (www.veeloop.com) that you may access directly or through another website, or by corresponding with us by phone, e-mail or otherwise. It only includes basic personal data required for you to be able to use our website, subscribe to our service, search for a product, place an order through our website, place an order through a retailer website and when you report a problem with our website. The information you give us may include your full name, address, e-mail address, phone number, financial and credit card information.
  • Information we collect about you. With regard to each of your visits to our website we will automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
  • Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies). We will notify you when we receive personal data about you from them and the purposes for which we intend to use that information.


IF YOU DO NOT PROVIDE US WITH YOUR PERSONAL DATA
If we need to process the data you provide us with about yourself to fulfil our service and you fail to provide that data when requested, we will not be able to fulfil your order. We will of course notify you if this is the case at the time.

COOKIES
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. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

HOW DO WE USE THIS INFORMATION?
We will only use personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where you have asked us to provide you with our services
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing to you directly, at any time by contacting us at hello@veeloop.com. However, before we email your child to let them know the status of their request, we will first ask you for consent. In order to give us your consent, you will need to first verify that you are the child’s parent or legal guardian.
  • Information you give to us. We will use this information:
    • 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;
    • to notify you about important changes to our service.
  • Information we collect about you. We will use this information:
    • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve our website to ensure that content is presented in the most effective manner for you and for your device;
    • to allow you to participate in interactive features of our service, when you choose to do so;
    • as part of our efforts to keep our website safe and secure;

Information we receive from other sources. We may receive personal data about you from selected third parties that we work with or that provide us with a service (such as payment services for example) and public sources (such as Companies House for example).

HOW DO WE SHARE YOUR INFORMATION?
You acknowledge and agree that from time to time we have the right to share your personal information with:
  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
  • Selected third parties including:
    • Stripe Inc. ("Stripe") based in the US, for processing payments;
    • Amazon Web Services, Inc. ("AWS"), for our IT hosting on their servers based in the EU;
    • Go Daddy Inc., (“GoDaddy”) based in the US, for our website hosting;
    • Xero Limited (“Xero”) based in the the EU, Australia, Singapore and the US, to issue our clients with invoices for services we provide them with;
    • Google analytics and search engine providers that assist us in the improvement and optimisation of our website;
    • Retailers that use VeeLoop to process payments for the products that are bought directly through their website.
    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.

We will disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If VeeLoop Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or to protect the rights, property, or safety of VeeLoop Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


WHERE DO WE STORE YOUR INFORMATION?
All personal data we process is processed by our staff and contractors who are based both in the UK and outside the European Economic Area (EEA).
Some of our external third parties such as Stripe, Go Daddy, AWS and Xero are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at hello@veeloop.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.
However and 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 at transmission stage; any transmission is at your own risk.

HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We are required under UK tax law where you have used our services, to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In some circumstances you can ask us to delete your data. See below for further information.

MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

MARKETING TO CHILDREN
We do not market directly to children without your explicit consent.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at hello@veeloop.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

THIRD-PARTY MARKETING
We do not currently share you details with any third parties for marketing purposes, but if we would like to do so in the future, we will first will get your express consent.
We will not share child data with any third party solely for their marketing purposes.

WHAT ARE YOUR RIGHTS?
If at any point you wish to know which information we are processing about you, or if you do not wish for us to process your information anymore or if you believe the information we process on you is incorrect or obsolete you can request to see this information and/or have it corrected or deleted by us by contacting us at hello@veeloop.com. We will fulfil your request to exercise your rights within a month and at no cost.

CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at hello@veeloop.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

CHANGES TO OUR PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail.