Trolleys24, a product of Digital Edge Services Limited (referred to as "Trolleys24," "our," or "we") operates within the realm of providing an Online Platform and Mobile Apps that facilitates the purchase, redemption, management, and storage of various non-reloadable digital gift cards, codes, and associated services (referred to as "Services").

This Policy outlines the procedures and guidelines that Trolleys24 will follow concerning the collection and management of your Personal Information associated with the Services.

Moreover, this Policy extends its applicability to the collection of Personal Information by Trolleys24 through its website, social media accounts, applications, software, and other technological platforms (referred to collectively as Platforms"). It also covers any direct communication between you and Trolleys24.

Trolleys24 employs both its own resources and third-party entities situated locally and internationally to deliver these Services.

Scope of this Privacy Policy

We prioritize the privacy of your Personal Information while using our Services. Our commitment to safeguarding your personal details and transaction details aligns with this Privacy Policy, which applies to all users of our Services and individuals whose Personal Information is processed by Trolleys24.

Our dedication to preserving privacy spans across our Platforms and Services. This includes transparently outlining the collection and storage of Personal Information, clarifying the reasons for its acquisition, detailing how we obtain this information, elucidating individual rights concerning their data in our possession, and adhering to relevant privacy laws. These laws encompass the GDPR, the Data Protection Act 2018, UK GDPR, and Privacy Laws, among others.

The Information we Collect

We may collect Personal Information that enables us to identify individuals and share such details.
The information we collect includes:
a) Personal Information - This includes an individual's name, location, and nationality for KYC purposes.
b) Contact Information - Our collection involves an individual's email address, Internet Protocol (IP) address, unique device identifiers, mobile number, device model and name, operating system, browser type.
c) Statistical Information - Our collection extends to behavioral and statistical data related to individuals and businesses using our Services and/or Platforms.
e) Geo-location Information - We acquire geo-location data to send service messages or exclusive offers from specific retailers based on the proximity of the customer to those retailers.

Why we collect Personal Information

We collect Personal Information so that we can carry out the following actions:
a) to enable you to use our Platforms;
b) to provide our Services;
c) to communicate with you, including about our Services and offers which might interest you;
d) to provide information or advice;
e) to process payments by or to you in connection with our Services;
f) to create accounts, tax invoices or receipts;
g) to provide your personal information to third parties in order for them to supply the Services to you;
h) to consider and respond to complaints made by you.
i) to communicate with you about research opportunities relating to our products and Services.
We may disclose additional purposes for collection of your personal information in collection statements at the point of collection.

How information is collected

Data is gathered when you engage with our Services, make an inquiry about Trolleys24, or interact with us directly or through our Online Platforms. Additionally, if you receive a Gift Card, information may also be obtained from the individual who bought the Gift Card for you.

When personal information is used and disclosed

We will solely use Personal Information for the intended purpose for which it was collected, unless otherwise authorized by the individual or as specified in this Privacy Policy.
The utilization of Personal Information may encompass, but is not restricted to:
a) Facilitating transactions related to the Online Platform, sharing your Personal Information with the selected Retailer/s chosen by you or the Gift Card recipient;
b) Seeking feedback regarding your Online Platform experience, its products, or other companies, and providing updates on news and promotions we believe may interest you;
c) Addressing your inquiries, comments, requests, and complaints to ensure effective customer service;
d) Monitoring and analyzing usage patterns and trends on the Online Platform;
e) Conducting analytics to enhance the Online Platform's functionality, market positioning, and user experience;
f) Investigating and preventing fraudulent or illegal activities;
g) Sending notifications concerning significant Online Platform changes;
h) Using information for the purpose it was gathered; and
i) Sending confirmations, updates, security alerts, additional product or service information, support, and assisting with Online Platform use.
Personal Information will be retained as necessary to fulfill the purposes stated in this Privacy Policy, unless lawfully required to be kept for an extended period.
We will not sell, provide, or share an individual's Personal Information with unrelated third parties unless:
a) The individual consents to the sharing of their Personal Information; and/or
b) In the context of any merger, sale, financing, or acquisition of Trolleys24 assets, where this information may be disclosed or transferred as part of Trolleys24's business assets.
There are specific circumstances where we may need to disclose an individual's information:
a) When we have reasonable suspicion of an individual's involvement in fraudulent, deceptive, or unlawful activity that should be reported to a governmental authority;
b) To enforce or apply our Privacy Policy, terms, conditions, policies, and agreements;
c) As mandated by law; and/or
d) In case of selling our business, where Personal Information may need to be transferred to a new owner.

Sensitive Information

Sensitive information pertains to details revealing your racial or ethnic background, political opinions, religious or philosophical beliefs, membership in professional or trade associations, affiliation with trade unions, health specifics, disability details, sexual orientation, or criminal record.

Our protocol involves collecting sensitive information only when reasonably essential for our operations or engagements. This collection occurs either with your explicit consent or when mandated or authorized by applicable laws.

Opting "IN" or "OUT"

By selecting "I Agree" or any similar button signifying your acceptance of this privacy policy, you explicitly agree to the gathering and utilization of your Personal Information as outlined within this privacy policy.

An individual holds the option to refrain from having their Personal Information collected (such as unsubscribing from marketing emails). However, this choice might limit or entirely prevent us from providing certain or all services. It could also result in the termination of their access to some or all services accessed through us.

Cookies

Temporary (session) cookies or permanent cookies might be utilized when accessing our Platforms and/or Services. These aid in recognizing your browser and monitoring the web pages you visit. Additionally, certain cookies enhance your browsing experience on our websites, aiding in navigation, feedback provision, and supporting our promotional and marketing endeavors. You have the option to disable cookies by adjusting your web browser settings.

The Safety and Security of Personal Information

a) Your personal information may be stored in either electronic or hard copy format.
b) If you furnish information to us electronically, it is retained within our computer systems and databases. For information provided in hard copy (paper), it's typically kept in our physical files, and a duplicate copy is generated for our electronic records.
c) Industry standard security measures are employed to protect and safeguard your information.
d) We might disclose your personal information to third parties and overseas service providers for various purposes, including utilization by overseas cloud computing hosts. Reasonable measures are taken to ensure these recipients adhere to privacy obligations regarding your information.
e) We hold no responsibility for the privacy or security practices of third parties, including Retailers, or those to whom we're permitted to disclose Personal Information in compliance with this policy or applicable laws. Such third parties may have separate privacy and security policies governing the collection and use of your information.
f) Should an individual suspect any misuse, loss, or unauthorized access to their Personal Information, they should promptly notify us.
g) In the event of any breach or potential breach of our security systems impacting your rights regarding Personal Information, we will inform you and relevant supervisory authorities as necessary.
h) We cannot be held liable for any loss, damage, or claims arising from another person's authorized use of the Personal Information provided by us.

How to access and/or update information

If you wish to modify or revise your personal information, kindly reach out to us using the contact information specified below, and we will proceed with the requested changes.
For security purposes, we might request verification of your identity to prevent unauthorized access to the personal information we hold.
Email: support@trolleys24.com
Telephone: +44 7756 591732

The right to be forgotten, deleting your account or personal data

You retain the right to delete your account or request the deletion of your personal data, with certain exceptions applicable. Trolleys24 offers the option to permanently delete your account or personal data anytime.
To initiate the deletion of your personal data or account, please inform us via the contact details outlined in this Privacy Policy or follow the prompts within the app. All deletion requests must be in writing.
What occurs when I delete my account or personal data?
Once your account or personal data is deleted, it becomes permanent and cannot be reinstated. This implies:
a) If you wish to continue using your Gift Cards, you must print them before deleting your account.
b) Our ability to assist you with customer service, such as in cases of lost or problematic Gift Cards, may be limited.
How long does it take to delete my account or personal data?
Upon receiving a request for account or personal data deletion, we will proceed to delete your account and associated data (and instruct our third-party service providers to do the same), unless mandated by regulatory or compliance obligations to retain such information. Some personal data might be retained by Trolleys24 or our third-party service providers post-account deletion to:
a) Maintain a record of the account deletion request and its execution;
b) Comply with relevant laws and legal obligations, including anti-money laundering and counter-terrorism financing regulations;
c) Adhere to internal security, fraud, and anti-money laundering policies;
d) Detect security incidents or prevent malicious, deceptive, fraudulent, or illegal activities;
e) Collaborate with law enforcement or regulatory investigations or directives; or f) Utilize the information internally in lawful ways compatible with its original context.
While most account or personal data deletion requests are typically processed within ten days, the complete deletion of all personal data may take up to 35 days.

Complaints and Disputes

If an individual wishes to get in touch with us or has concerns regarding our handling of their Personal Information, they should direct their communication in written form to the contact information provided below:
Privacy Officer at Trolleys24
Address: 28 Platford Green, Hornchurch, England, RM11 2TA
Email: hello@Trolleys24.com
In case of a dispute concerning an individual's Personal Information, both parties must initially make an effort to resolve the matter directly between them.
Upon discovering any unauthorized access to an individual's Personal Information, we will promptly notify the affected individual and any necessary supervisory authority once we have determined the nature and method of the unauthorized access, at the earliest viable

Location-based Data

If Trolleys24 integrates any location-based functionality within its Services, it might gather, utilize, and disclose precise location information, encompassing real-time geographic data from your computer or device. Location-based services, when accessible, may utilize GPS, Bluetooth, IP Address, and technologies like crowd-sourced Wi-Fi hotspot and cell tower locations to approximate your device's location. Unless consent is provided, this location data is collected in a manner that does not personally identify you.
We offer a geo-push notification feature via a mobile app, delivering service messages or exclusive offers from certain retailers based on the customer's proximity to those retailers. This functionality necessitates access to the mobile device's location services, which must be manually enabled by the customer. Trolleys24 does not retain real-time location data nor utilize location services for any purpose other than the geo-push notification feature.

GDPR

If you access our Online Platforms or utilize our Services within the European Union or the United Kingdom, Trolleys24 is obligated to adhere to the GDPR concerning your Personal Information.
Any mention of Personal Information in this Privacy Policy also pertains to Personal Data as defined under the GDPR.
Trolleys24 places considerable emphasis on the security and confidentiality of your Personal Information. We have formulated this privacy policy and implemented measures to collect, process, and store all Personal Information in accordance with Privacy Laws and the GDPR, irrespective of the user. Consequently, no supplementary terms are necessary for GDPR users.

Additions to this Policy

In the event of modifications to this Privacy Policy, we will communicate these changes on our website and Mobile app. Kindly revisit this Privacy Policy to review any updates or alterations.

Trolleys24 (a product of Digital Edge Services Limited)
Policy Version: July 2023