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My Club Europe PLC Privacy Statement
This Privacy Statement pertains to the personal information we collect or generate about our customers in our stores, on our websites, or via mobile apps. This Privacy Statement describes the types of information collected, and how your information is used, shared, and protected. It also explains the choices you have relating to your information and how you can contact us.
The categories of information about you that we may collect, use, disclose and otherwise handle may vary by country and applicable law. Typically, we will collect, store and process information about you if you use our websites to view or buy products, e-vouchers or gift cards, or if you voluntarily provide us with such information, for example when you subscribe to our mailing list, enroll in our loyalty programme, enter a promotion or competition, contribute content about yourself to our websites, whether by direct upload, posting such content to one of our social media pages or by using a hashtag or other identifier that we use to integrate social media content with our websites, or if you apply for a job or take part in inquiries or surveys. This information will be processed by electronic means and includes:
- contact details including name, e-mail, telephone number and address;
- login and account information, including screen name, password, and unique user ID;
- personal details including gender and date of birth;
- payment or credit card information;
- personal preferences including your marketing and cookie preference;
- content you may provide via a form on our websites;
- your image and any personal information that you include in content that you contribute to our websites (such as comments, photos, and videos) as well as the name of the social media account from which you contribute that information; and
- other personal information you provide to us on our websites, via mobile apps, on feedback forms, in our stores or when you interact with us in other ways, both online and offline.
Subject to applicable law, we may collect, use, disclose or otherwise handle your information in pursuit of our legitimate business interests while maintaining appropriate technical and organizational measures to protect the information. These interests include to:
- enable the use of and make improvements to our websites;
- send direct marketing materials to you if you have agreed for us to do so;
- operate, evaluate, and improve our business and websites;
- manage customer, supplier, and vendor relationships;
- enroll you in and administer our loyalty and other rewards
- programs upon your request;
- improve merchandise selections and customer service;
- identify your product and service preferences;
- notify you about new products, services, features, promotions, events, and special offerings relating to My Club Europe PLC that we think you will find valuable; and
- administer your participation in promotions, contests, and sweepstakes.
Where we have a contract with you, we process your personal information as necessary for performance of the contract. This includes to:
- process business transactions and related activities; and
- supply our goods and services.
We also may use the personal information we collect to protect us against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal and regulatory requirements, industry standards, and our policies and terms. We use personal information for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by a law that applies to us. This includes to:
- verify your identity in certain instances (such as when you return merchandise or request a refund);
- meet any legal and regulatory requirements; and
- secure our operations and protect against, identify, and help prevent fraud, unauthorized activity, claims and other liabilities and minimize risk.
If we plan to use the personal information that you provide to us for other purposes beyond those described above, we will provide you with information about that processing at the time of collection.
We do not sell, otherwise disclose, or share information we collect and hold about you, except as described in this Privacy Statement.
We share personal information with third parties who perform services on our behalf. We use third parties to host our websites or mobile apps, operate certain of its features, send e-mails, print, or send mailings, run our sweepstakes, contests or other promotions, conduct customer research, authorize, and process your payments, manage, +and analyze data and our advertising effectiveness, provide customer support, manage customer claims, prevent fraud, protect our assets and data, and fulfill orders. These third parties are not authorised by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Any personal information shared with such third parties is protected as described below.
Subject to applicable law, we may also share the personal information we obtain with our affiliates, subsidiaries and other group companies for the purposes described in the prior paragraph. If we share your personal information with such entities, we will ensure that an adequate level of protection is in place to protect your personal information in accordance with applicable law.
We also may disclose information about you: (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena) including lawful requests by public authorities to meet national security or law enforcement requirements; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights; or (iv) when we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual illegal activity.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation), but only where we have first taken reasonable steps to ensure the security and confidentiality of your information.
We maintain appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure, or access. However, we cannot guarantee the effectiveness of these safeguards, and nothing in this notice shall be construed as an express or implied warranty against loss, misuse or unauthorized access, disclosure, alteration, or destruction.
Service providers who might have access to your information to provide services on our behalf will be contractually obliged to keep such information in confidence, implement adequate data security measures, and may not use that data for any other purpose.
Our websites may contain links to other third-party websites. These websites may operate independently from us. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked website or applications. We are not responsible for the content, use or privacy practices of any website or applications that are not affiliated with us.
We take reasonable steps to ensure that the information we process is reliable for its intended use, is accurate, up-to-date, and complete, and is limited to the information required to carry out processing for the purposes described in this Privacy Statement. We retain your information for as long as necessary to fulfil the purposes for which we collect it, except if required otherwise by law.
We may transfer to and store the information we collect about you in countries other than the country in which the information was originally collected, including the United States and other destinations outside the European Economic Area (“EEA“), in accordance with applicable law. Those countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to other countries, we will protect the information as described in this Privacy Statement and comply with applicable legal requirements providing adequate protection for the transfer of information to countries outside the EEA. This includes by entering the European Commission’s EU Standard Contractual Clauses with the data recipient or ensuring that the data recipient has implemented Binding Corporate Rules. To obtain a copy of the safeguards we have put in place, please contact us as indicated below.
Subject to applicable law, you may have certain rights with respect to our processing of your information. You may have the right to request access to the information we hold about you, obtain confirmation as to whether information concerning you exists, be informed of the content and source of such information, and check its accuracy. In addition, subject to applicable law, you have the right to correct, update, erase, restrict, or object to the use of, your information held by us.
Also subject to applicable law, you have the right to receive a copy of your personal information in a structured, commonly used, machine readable format, including a right to have that personal information transmitted to another organization.
If you change your mind and no longer wish to receive marketing communications from us, you have the right to request that we cease sending marketing communications, whether by e-mail or otherwise, to you. You can do this by:
- checking the applicable box(es) on any form we may use to collect information from you.
clicking the unsubscribe link displayed in any of our marketing e-mails; or
- otherwise requesting that we do not process your information for marketing purposes.
- You can withdraw any consent given to us at any time and free of charge, but you may no longer be able to benefit from our services if you do so.
To exercise these rights or to make a complaint or submit an inquiry about our privacy practices, please contact us or write to us at:
Data Protection Officer
My Club Europe Plc
2 Oxted Chambers,
185-187 Station Road East,
Oxted Surrey RH9 0QE
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.
You also may lodge a complaint with the data protection authority in your country if you are not satisfied with our response.