Licklist Privacy Policy

Publication Date:1st May 2018

What does this policy cover?

This policy describes the processing of your personal data in relation to your use of the website www.licklist.co.uk or the Licklist app on iOS and Android ("platform") by Licklist Holidings Limited (09933601 WeWork Aldgate Tower, 2 Leman Street, London, E1 8FA) ("we", "us" or "our"), as the owner and operator of the website and app.

For the purposes of applicable data protection law (including, the General Data Protection Regulation 2016/ 679 (the "GDPR"), we are a 'data controller' of your personal data.

Where applicable, this policy should be read alongside Licklist's terms and conditions which tell you about the terms on which you may use the platform.

What personal data is collected?

1. Personal data collected from you:

   The following categories of personal data will be collected about you in connection with your use of the platform and your interaction with us, including, but not limited to, when you fill in forms on the platform or provide us with information whilst in a bar or club, and submit user-generated reviews or ratings, engage in any social media functions on the platform, make transactions in a participating venue using a card linked to the Licklist loyalty app:

   • Personal Identification Information: such as, your name, date of birth, gender;
   • Contact Information: such as, email address and telephone number;
   • Demographic Information: such as, postcode;
   • Preference information: such as, favourite music, favourite venues, favourite drinks;
   • Spending habbits and drinking habbits based on transactional data;
   • Venues you visit and frequency of visit;
   • Social media identification information, such your Facebook page address, your Twitter handle, your Instagram handle and profile picture;
   • Photographs of you; and
   • Your marketing preferences, including any consents you have given us.

   In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.

   Please note that Licklist will not store credit or debit card information from payments made through our services other than where it is necessary for us to complete our obligations to you.

2. Personal data collected about you:

   • From Others: Although we generally collect personal data directly from you, we also collect certain categories of personal data about you from other sources.
   • Automatically Collected Information: [such as, web browser type and version, operating system, the platform you came from and exit to, your IP (Internet Protocol) address, your browser settings, the date and time of your visits, and details regarding your interaction with the platform (including which pages or resources on the platform you access);]
   • Cookies Information: in accordance with the Cookies section below.

   We may collect information about you from other sources. This may include for example information you have shared publicly, including on social media.

   In addition, you can also create your Licklist account using, or connect your Licklist account to, your accounts on third party services such as Facebook, Twitter or Instagram. In the event that this occurs, we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy. For example, if you connect with our platform using Facebook, we store your Facebook I.D., your first name, surname, email, location, pages you have "liked" and profile picture we can see which brands you have liked on Facebook and invite you to follow them on Licklist.

   This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.

   Sometimes you will have given your consent for other websites, services or third parties to provide information to us.

   For example, this could include information we receive about you if you follow a Promoter's or Venue's page/website we operate or any other services we provide, in which case we will have informed you when we collected this data that it may be shared. We will also have told you for what purpose we will share your data.

   It could also include information from third parties that we work with to provide our products and services, such as payment processors, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.

   As a Customer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of a Promoter/Venue.

   As a Customer we will collect additional Personal Data from you, sometimes for our own purposes and other times on behalf of a Promoter/Venue.

   Also, Promoters and Venues can create event registration pages to collect information from Customers regarding their registration for a Promoter's/Venue's event listed on our Services. Licklist does not control the Promoter's/Venues registration process nor any Personal Data that a Promoter/Venue collects. Personal Data collected on behalf of Promoter/Venue is provided to the Promoter/Venue of the applicable event in accordance with the provisions set out below.

How is your personal data used, and what is the legal basis for this use?

We process your personal data for the following purposes:

• Contractual Necessity: As required to establish and fulfil a contract with you, for example: if you make a purchase from us (this will include taking payments); communicating with you and providing customer services; and in order to administer our loyalty programme.

• Legitimate Interests: As required by us to pursue our own legitimate interests, in particular:

  • facilitating the creation of, and securing, online registered accounts
  • managing, operating and improving online registered services (incl. enabling you to manage your marketing preferences), and customer journeys on the platform;
  • monitoring any online feedback/reviews to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  • delivering tailored advertising (incl. via Facebook look-a-like and custom audience);
  • we will use data in connection with legal claims which concern our company, group or partners, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
  • creating user / customer insights based on transactional behaviour segments to drive targeted direct marketing;
  • creating user / customer insights based on demographic segments to drive targeted email direct marketing and also carrying out market research and surveys;
  • communicating with you; and
  • investigating and handling any complaints received from you about our platform, or our services.

You can obtain further information on the legitimate interests balancing exercises which we have carried out by contacting us using the contact details provided below.

• Legal Compliance: To ensure compliance with applicable laws and legal processes including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation and to law enforcement agencies).
• Consent: Subject to the following, we will send you direct marketing by email, SMS, push notifications, telephone, post, in-App and online about Licklist services which we think may be of interest to you. This will only be sent where you have given your consent to Licklist during the online sign-up process or verbally, or (where permissible) you have been given an opportunity to opt out. You will be able to opt-out of electronic direct marketing by clicking the unsubscribe link contained in the email itself and, in all other cases, by updating your preferences on the Licklist platform.

Minors

[Visitors under 18 years of age are not permitted to Subscribe to our services use and/or submit their personal information on any of our website or applications. We do not knowingly solicit or collect information from visitors under 18 years of age.] We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Who will your personal data be shared with, and where?

We will share your personal data with:

• third party service providers, who will process it on our behalf for the purposes above. Such third parties include, but are not limited to, couriers for delivery of your orders, customer service operations, and marketing providers;
• government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our own legitimate interests in compliance with applicable laws; and
• purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
• Licklist partner venues for marketing campaigns providing the relevant consent has been given
• We share the information that you provide to us with our staff so that we can provide our products and services to you.

Where we store your Personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside the 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 may be 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. Licklist will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, our terms of use and the applicable data protection legislation

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted (using SSL technology). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 site; 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.

In addition, where you are a Promoter/Venue and import your database of personal information into our system, your database is stored on our secure servers. We do not, under any circumstances, sell or give access to your database. If an individual whose information is on your database complains or contacts us, we might then contact that person. Only authorised employees of Licklist have access to view this Personal Data. Please note that you may export (download) your database from us at any time.

Please note, if we detect abusive or illegal behaviour related to your database, we may share your database or portions of it with affected ISPs or anti-spam organisations.

Where we act as a data processor

If a Venue/Promoter imports its own database or other contact information it has collected into the Server, that database shall remain owned by that Venue/Promoter. The Venue/Promoter shall be the Data Controller in relation to any Personal Data collected pursuant to this clause. Licklist will be a Data Processor of this data and shall comply with its obligations as a Data Processor.

Further to this, the Venue/Promoter warrants that, where it is a Data Controller, it shall provide each Data Subject with the required information as set out in Article 14 of the GDPR, including but not limited to the identity and contact details of the Venue/Promoter, the purposes for processing their information and the categories of personal data with which the Venue/Promoter is concerned.

The Venue/Promoter warrants that it has all consents required to allow it to import its database referred to above into the Server and to allow Licklist to process such Personal Data in accordance with these Terms and the terms of the Privacy Policy.

If a Customer, or other User, creates an account on the Lickist platform and follows a Venue/Promoter (including a Data Subject who was initially introduced to the Service through the importing of a database), that User's data shall become part of Licklist's database.

Where the above occurs, both Licklist and the Venue/Promoter shall be referred to as a Data Controller in relation to any Personal Data provided by a User.

Any questions you may have in this set of circumstances regarding the use of your data should be directed at the Venue/Promoter. Where you no longer wish to be contacted by a Venue/Promoter through our platform, you can unsubscribe from any communications you receive from Licklist. In addition, in these circumstances, where you wish to update any inaccuracies in your Personal Data on our system, or wish for your Personal Data to be deleted from our system, you can contact either us or the Venue/Promoter.

Venues/Promoters are allowed to use our system to contact Customers of their current and past events, so you may receive emails from our system that originate from such Venues/Promoters that we send on their behalf. If a Customer registered for an event using our platform, their email address is available to the Venue/Promoter of that event.

Venues/Promoters may also import contact information they have from external sources and send communications through our platform to those individuals, we will deliver those communications to those individuals on the Venues/Promoter’s behalf. The Venue/Promoter and not Licklist is responsible for sending these communications. The Customer has the right to opt out of such communications at any time.

Venues/Promoters may also partner with other Venues/Promoters on the Licklist platform to Co-Promote events whereby they recommend similar events by other Venues/Promoters to their Customers.

In addition to the above, there are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

• required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;
• necessary to protect the safety of our employees, our property or the public;
• necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; and
• proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.
• Sometimes, we share your information with our third-party providers, who help us provide and support our Services. Examples of third-party providers include payment processors, email marketing platforms, hosting services and content delivery services. We have contracts with each of these providers that specify that they will only use your data for the purposes of performing the services we have contracted them for. Anonymised data is also used for the purposes of website and app analytics.

Cookies

What cookies will be used on the platform?

The platform uses (first party and third party) cookies (small files placed on platform users’ hard drive) to distinguish you from other users of the platform. This helps us to provide you with a high quality experience when you browse the platform and also allows us to improve the platform. We use cookies to analyse the flow of information; customize the services, content and advertising; measure promotional effectiveness; and promote trust and safety.

We don't have access to the cookies which third parties place on the platform; other than allowing them to be served. Such companies have their own privacy policies which we encourage you to review.

More detail on how businesses use cookies is available here. We offer certain services that are available only through the use of cookies. Generally, there are the following categories of cookies:

Strictly Necessary Cookies

Some cookies are essential for the operation of the platform. For example, some cookies allow us to identify registered users and ensure they can access the platform. If a registered user opts to disable these cookies, the user may not be able to access all of the content of the platform.

Performance Cookies

Other cookies may be used to analyse how users use the site and to monitor site performance. This allows us to provide a high quality experience by customising the offering and quickly identifying and fixing any issues that arise. For example, performance cookies may be used to keep track of which pages are most popular and to determine why some pages are receiving error messages.

Functionality Cookies

Functionality cookies are used to allow us to remember users’ preferences and tailor the platform to provide enhanced features.

Targeting Cookies

Targeting cookies are used to serve users with adverts, and to collect information about users' browsing habits and usage of the platform in order to make adverts more relevant to users and their interests. We may use remarketing technologies to enable third parties to display relevant and personalised ads to users through their networks. They are also used to limit the number of times users see an advert as well as help measure the effectiveness of an advertising campaign.

Social Media Cookies

These cookies allow users to share what they've been doing on the platform on social media such as Facebook and Instagram. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

Google Analytics

Google Analytics is a web analysis service provided by Google, Inc. We use Google Analytics to monitor how visitors use our platform, to compile reports and to help us improve the platform. Please see Google’s privacy policy here for further information on the data Google collects and how it is processed. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-Out Browser Add-On by following the instructions here. You may opt out of Google's use of tracking technologies by visiting the Google advertising opt-out page here. For more information on opting out of third party vendors' use of cookies please visit Your Online Choices here.

Facebook Ads

We use Facebook services to deliver our ads to you during your browsing experience whilst you are online. You can control how Facebook uses data to show you ads by turning off ads which may be based on interests and / or your relationship with specific advertisers, in your ad preference settings. For further information, please visit the various Facebook pages which allow you to learn more about Facebook ads and tracking technologies and to update your settings:

• https://www.facebook.com/policies/cookies
• https://www.facebook.com/about/ads
• https://www.facebook.com/ads/preferences/edit

Further, by visiting the Your Online Choices link above, you can opt out from seeing Facebook's interest-based ads and you can also use your mobile device settings to configure your advertising preferences.

On your Facebook ad preferences, you will see that ads may be delivered to you according to 'interests' or specific advertisers and you can manage your ad preference settings for both of these.

Please note that where you have opted out of receiving our email marketing communications via the methods described above, you may still see our non-targeted adverts whilst you are online, if your interests settings on Facebook are aligned to an audience segment (pre-defined by Facebook) which our business is also associated with. We do not control whether these ads are displayed to you. Please see the relevant links above for details on how to learn more and manage Facebook ad settings.

Further, to learn more about adverts which are displayed to you whilst you are online, please consult the applicable platform's privacy and cookies policy on which you see our ads and the Your Online Choices link above.

Users are always free to decline cookies if their browser permits, although doing so may interfere with their use of the platform. Please find detailed information on how to disable cookies here.

Smartlook

We use Smartlook to record screen activity and actions by you when you use the Licklist app. All personal information is hidden and we use these recordings to help with bug fixes and to improve the product.

Changes to this policy

Any changes we may make to the policy in the future will be posted on the platform and, where appropriate, notified to you by email or otherwise. The changes will be also available in hard-copy at our premises.

Contact us

If you have any questions about this policy and / or our processing of your personal data, please contact us at [email protected]

Where can I find more information about the handling of my personal data?

See our fuller Privacy FAQs for further details on your rights, retention periods, and international transfers.