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Privacy Policy

Welcome to the Picnic privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website(s) and/or use of app(s) (together, Services) (regardless of where in the world you visit it from) and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy explains how Picnic processes your personal data through your use of our Services, including any data you may provide when using our Services.

Our services are not intended for children to access and we do not knowingly or intentionally collect data relating to children under the age of 16.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

Picnic Ventures Ltd is data controller of and is responsible for the personal data described in this privacy policy. Picnic Ventures Ltd is referred to as “Picnic” "we", "us" or "our" in this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights in relation to your personal data, please contact us using the details set out below.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please do contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Services 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 Services, we encourage you to read the privacy policy of every website that you visit and app that you use.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, email address, phone number, age and gender.
  • Contact Data includes email address and telephone numbers.
  • Communications Data includes the content of all communications sent or received by you via our Services including any media, photos or videos included in those communications.
  • Technical Data includes information about your IP address, browser type, app version, device type and other data about the devices you use to access our Services.
  • Usage Data includes information about how you use our Services, including communications you send and receive.
  • Marketing and Communications Data includes your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not directly collect any Special Categories of Personal Data about you and we do not collect any information about criminal convictions and offences. However Special Categories of Personal Data may be included in Communications Data and, to the extent it is, you give you consent for us to use that data for the purposes specified in this policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

3. How is your personal data collected?

We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Communications and Usage Data by filling in forms or by corresponding with us by post, phone or email or by using our Services.
  • Automated technologies and indirect interactions. As you interact with our Services, we will automatically collect Technical Data. We collect this personal data by using first and third party cookies and other similar technologies. Please see our cookie policy for further details.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

The section below contains information about the lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below a description of all the ways we process your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer
  1. Identity
  2. Contact
Performance of a contract with you
To operate and provide our Services
  1. Identity
  2. Contact
  3. Communications
  4. Technical
  5. Usage
  6. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to develop and grow our business, invite users to join beta trials and to analyse how customers use our Services)
To manage our relationship with you which may include notifying you about changes to our terms or privacy policy
  1. Identity
  2. Contact
  3. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated)
To administer and protect our business and Services
  1. Identity
  2. Contact
  3. Communications
  4. Technical
  5. Usage
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
  2. Necessary to comply with a legal obligation
To enhance our Services and user experience
  • Technical
  • Usage
  • Necessary for our legitimate interests (to define types of customers for our Services, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy)
    To comply with legal, audit or financial obligations
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    1. Necessary for our legitimate interests (to manage, develop and grow our business)
    2. Necessary to comply with a legal obligation

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send you marketing communications where we have obtained your consent to do so. You can ask us to stop processing your personal data for this purpose at any time.

    Cookies

    We occasionally use functional cookies on our Services when required to enable the Services to operate as intended.

    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 have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    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.

    5. Disclosures of your personal data

    When required for the purposes stated above, we may share your personal data with:

    • Our business partners, customers, suppliers, service providers and sub-contractors who provide us with various services required to run our business.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide us with professional services.
    • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and in other jurisdictions, when required.
    • Analytics and search engine providers that assist us in the improvement and optimisation of our site, although this will not include Identity, Contact or Communications Data.
    • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    International transfers

    We may share your personal data with our service providers based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate contractual safeguards are in place.

    6. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    7. Data retention

    How long will you use my personal data for?

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

    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, regulatory, tax, accounting or other requirements.

    In some circumstances we will 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.

    8. Your legal rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are described in detail below.

    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons.

    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

    What we may need from you

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

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    Cookie policy

    Our website(s) and app(s), (together, our Services) use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our Services and also allows us to improve our Services.

    A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. We use the following cookies:

    • Strictly necessary cookies. These are cookies that are required for the operation of our Services. They include, for example, cookies that enable you to log into our Services.
    • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Services when they are using them. This helps us to improve the way our Services work, for example, by identifying any persistent issues with our Services.
    • Functionality cookies. These are used to enable parts of the service to function, for example by sending push notifications
    • You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
    Cookie Name Purpose
    Authentication Token A Strictly necessary cookie, used to tie all communications from a single device to a particular user. This token is stored securely on your device while logged into Picnic, for the duration of being logged in. The token can be changed by logging out, but is associated to your identity via your phone number. It is also used to link your technical and usage data to your account.
    Notifications Token A Functionality cookie, used to send push notifications via Firebase Cloud-Messaging (FCM) and Apple Push Notification Service (APNS). You can opt out of this by disabling push notifications in-app.

    Please note that third parties, including Google and other providers of external services like web traffic analysis services, may also use cookies on our Services. These third party cookies are likely to be analytical cookies or performance cookies.

    You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Services.

    Updated: Friday 19th March 2021