1 Introduction

 

1.1 High50 is committed to protecting the privacy of our users. This Privacy Policy is intended to inform you how we gather, define, and utilise your Information (as defined below). This policy is intended to assist you in making informed decisions when using our website, www.high50.com (the “Website”) and our products and services. Please take a minute to read and understand the policy.

1.2 This Privacy Policy and our separate Cookies Policy are incorporated into and form part of our Website Terms of Use.

1.3 Capitalised terms in this Privacy Policy shall where the context admits or requires have the meaning ascribed to them in the Terms of Use.

 

2 What information do we collect and why?

 

2.1 All your Information shall be held and used in accordance with the Data Protection Act 1998 (the “Act”) where applicable.

2.2 When you visit our Website you may provide us with your name, user name; date of birth; gender; address; email address; and IP address (together, the “Information”). You may provide us with this Information in a number of ways:

(a) by supplying us with the Information, as listed above, on an individual basis when creating an account, updating your profile, subscribing to receive updates from us or posting comments or content in applicable sections of the Website (including any of our blogs or forums);

(b) when you enter a competition or promotion of ours featured on the Website (as opposed to a Partner Offering);

(c) if you choose to correspond with us by email, we may retain the content of your email messages together with your email address and our responses;

(d) if you advise us of any preferences and areas of interest on subscribing to our services; and

(e) by providing Information to us in any optional surveys and opinion polls that we use for research purposes.

2.3 We may collect information about your computer, including where available your IP address, operating system and browser type and the geographical location of your computer, for system administration and to report aggregate information to our advertisers. This is statistical data about browsing actions and patterns and does not identify you as an individual. Please see our Cookies Policy for further details.

2.4 High 50 Limited is the data controller of your Information for the purposes of the Act. High 50 Limited is a company registered under number 08037475 in England and whose registered office is at Circus House, 2nd Floor, Great Titchfield Street, London, United Kingdom, W1W 8BA and shall ensure that your Information is processed and held in accordance with the Act.

2.5 We use your Information in the following ways:

(a) to ensure that content from our Website is presented in the most effective manner for you and your computer;

(b) to contact you in accordance with your authorisation as expressed when you create an account with us, subscribe to our newsletter or any other online service, post comments or content to our Website, or correspond with us;

(c) to allow you to participate in any interactive features of our service, when you choose to do so; and

(d) to notify you about any changes to our service.

2.6 From time to time our Website may contain links to a Partner website or to Partner Offerings on third party websites. Please remember that when you use a link to go from our Website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which are linked to ours is subject to that website’s own rules and policies. Please read those rules and policies before you submit any personal data to these websites.

2.7 We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example we may inform them that 500 people in the Manchester area have clicked on their advertisement on any given day). Please see our Cookies Policy for further details.

2.8 In limited circumstances we may pass your Information to other third party organisations:

(a) if we buy or sell any business or assets in which case we may disclose your Information to the seller or buyer of such business or assets. This includes the transfer of personal information as a standalone asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control, such transfer to be made without obtaining your consent

(b) if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply our Terms of Use and other agreements or protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction; and

(c) where we have obtained your prior consent.

2.9 Please note that by posting any Information in any publicly accessible area of the Website such as in comments or any of our blogs or forums, such Information may be viewed and collected by third parties over which we have no control. We are not responsible for the use of Information by such third parties. Please therefore exercise all due care and consideration before disclosing any Information that will be accessible on public areas. We strongly recommend you keep postings anonymous and avoid disclosing Information that may be used to identify you.

2.10 Any information we collect may be retained for an indeterminate period of time.

 

3 Your rights

 

3.1 You may request access to all your Information that we collect online and maintain in our database by emailing [email protected]. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

3.2 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected].

 

4 Your consent

 

4.1 By using our Website you consent to our collection and use of your Information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our Website to keep you aware of what Information we collect, how we use it and under what circumstances we may disclose it.

4.2 You also acknowledge that if you enter into any online competitions or prize draws, any entry information provided by you, such as your name and/or email address, may be used by us to publicly identify you as the winner or runner-up of the relevant competition or prize draw, on the Website or through social media and you, by entering into such competition or prize draw, consent to such use.

 

5 Where we store your information

 

5.1 The Information that we collect from you may be transferred to and stored at a destination outside the European Economic Area. Your Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, managing subscription services and analysing statistical data about browsing actions and patterns. By submitting your Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Privacy Policy.

 

6 Security

 

6.1 We maintain the highest standards of security, however the transmission of information via the internet is not completely secure. Any transmission is at your own risk. Once we have received your Information, we will use strict procedures and security features to prevent unauthorised access.

6.2 All information you provide to us is stored on our secure servers. 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.

 

7  Changes to our Privacy Policy

 

7.1 Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

7.2 All versions of the Privacy Policy are dated with the effective date of that version of the Privacy Policy (i.e. the date on which the applicable version of the Privacy Policy was posted to the Website). High50’s use of information it learns about you will be governed by the most recent Privacy Policy in effect.

 

8 Contact

 

8.1 Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected].

 

9 Your opt-out and ‘Do Not Track’ rights

 

9.1 Do Not Track is a voluntary programme among Internet advertisers that is intended to give users the ability to opt out of behavioural targeting and advertising. There are a few ways in which your computer may send a “do not track” signal to certain websites and online services you visit, including by disabling cookies. High50 does not honour Do Not Track settings because we do not, at present, perform any meaningful behavioural targeting or behavioural advertising. If you do not agree with High50’s policy not to honour Do Not Track, your only remedy is to immediately stop using www.high50.com.

 

10 Requests under the ‘Shine The Light’ Law

 

10.1 California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our shoppers who are California residents to request and obtain from High50 once a year, free of charge, information about the personally identifiable information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: High50 Limited, Circus House, 2nd Floor, Great Titchfield Street, London, United Kingdom W1W 8BA.

10.2 Please be aware that not all information sharing is covered by the ‘Shine the Light’ requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to a shopper’s request once during any calendar year.

For an explanation of our overall privacy practices please review our privacy policy.

 

11 Children’s Privacy Statement

 

11.1 This section explains our practices with respect to the online collection and use of personally identifiable information from children under the age of 13, and provides information regarding their rights under federal law with respect to such information,

11.2 The Website is not directed to children under the age of 13 and we do NOT knowingly collect personally identifiable information from children under the age of 13 as part of the Website, nor do we knowingly distribute such information to third parties.

11.3 If we become aware that we have inadvertently received personally identifiable information from a user under the age of 13, we will take the appropriate steps to delete such information from our records, We do NOT knowingly allow children under the age of 13 to publicly post or otherwise distribute personally identifiable information through the Website.

11.4 Because we do not collect any personally identifiable information from children under the age of 13 via the Website, we do NOT condition the participation of a child under 13 in the Website’s online activities on providing personally identifiable information.

 

12 Correcting your information

 

12.1 If you are a registered user, you can log in to your account at any time to see what personally identifiable information you have provided and you may update or otherwise correct it. If you have questions about your information, feel free to email us with questions at [email protected] or send a written request to our postal address for correspondence at High50 Limited, Circus House, 2nd Floor, Great Titchfield Street, London, United Kingdom W1W 8BA. We will take reasonable efforts to respond in a timely manner.  

Last updated December 2014