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Privacy

INVITATION DIGITAL LIMITED PRIVACY STATEMENT FOR CLIENTS

Effective Date: 17 November 2023

This Privacy Statement (“Privacy Statement”) explains how Invitation Digital Limited of First Floor, Merchants House North, Wapping Road, Bristol BS1 4RW ( “us”, “our”, and “we”), collects, controls, processes and use information about you (which we call “personal data”). For the avoidance of doubt, “personal data” in this context means data about individuals (not companies) and excludes business information, such as a registered office address.

Invitation Digital Limited is the operator of this website, and a provider of a range of services. We provide a platform (including this website) through which you can contact and register with us for the purposes of doing business with us.

This Privacy Statement applies to: (a) information we collect through our websites, mobile applications, electronic communications or services, social networking sites, or any individual, business partner-specific, merchant-specific, city-specific, or other area-specific websites we offer that link to or reference this Privacy Statement (collectively, the “ Site”); (b) information you provide to us in any contractual documents you are required to sign that link to or reference this Privacy Statement; and (c) any other information you provide to us in a different format, for example, over the telephone.

We will routinely update this Privacy Statement to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functionality or features to the Site. If we make any material changes we will notify you, either by email (sent to the email address specified in your account), by means of notice on the Site or otherwise. You can determine when this version of the Privacy Statement was adopted by referring to the “Effective Date” above.

SITUATIONS IN WHICH WE COLLECT INFORMATION

We will collect the following information from you when you interact with us through the Site:

  • your email address, physical address and password for our website, if you register. This information is necessary for us to create an account for you and for us to comply with our obligations to you under the Terms of Use, and if you do not provide this information, we will not be able to create an account for you;
  • your password for accessing the data-reporting portal and/or self-service platform if you use either of these tools;
  • your bank details in the event that you enter into a contract with us that requires us to pay you. This information is necessary for us to pay you in accordance with our contract with you, and if you do not provide it we will not be able to pay you;
  • other information you actively send to us (e.g., via email or via instant messenger chats with our business consultants).

We will also collect the following information about you automatically when you interact with the Site:

  • your IP address;
  • information about how you interact with the Site, including website browsing preferences, details of how you interact with the Site and emails we send to you and how you interact with our ads or other content on other pages online (e.g., through cookies and other types of device identifiers);

Finally, we may obtain personal data and other online and offline information from publicly available sources, such as your website and LinkedIn profiles and similar sites.

We will collect the personal data described above at various stages in your relationship with us, for example, when you: *register, subscribe, authorise the transfer of, or create an account with us; *open or respond to emails from us; *provide information to enter into a contractual agreement with us or as necessary to provide services you have requested.

HOW WE USE INFORMATION

We control and process the personal data you provide to us, which we collect from other sources and generate in order to:

  • Provide the services we offer as set out in the client agreement, including allowing you to run offers, promotions, products and services with a gift card as a reward;
  • Operate, maintain and improve the Site by analysing how you and our other clients use it. This is to meet our legitimate business interests in providing the Site and ensuring that it provides the best experience for our clients;
  • Provide you with access to the Groupon Data Reporting Portal and/or The Hub self-service platform
  • Contact you to discuss existing or potential future commercial agreements;
  • Carry out marketing, which may involve sending you direct marketing messages and other communications that may be of interest to you via email. We will either send these messages on the basis that you have consented to receiving them or, where permitted by applicable law, to meet our legitimate interests in showing you which of our products and services are most relevant to you;
  • Answer your questions and respond to your requests, for example in the context of providing services to you. This is to meet our contractual commitments to you where these questions or requests are part of the process of providing services to you, and in other cases to meet our legitimate interests in providing a good service to our merchants;
  • Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, and requested information. This is to meet our legitimate interests in managing our relationship with you effectively;
  • Manage our everyday business needs, such as administration of the Site, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use or to comply with the law;
  • Comply with our legal obligations, resolve disputes, and enforce our agreements. We do this where necessary to comply with legal obligations to which we are subject, or to meet our legitimate interests in enforcing our legal rights and resolving disputes.

WHEN AND WHY WE DISCLOSE INFORMATION

We will not share or sell your personal data, except with your consent or as otherwise required or permitted by law, as follows

  • with affiliated and unaffiliated service providers within and outside of the United Kingdom, including, without limitation, Groupon, Inc. which has its registered offices at 600 West Chicago Avenue, Chicago, Illinois – 60610, USA, and will process your personal data only in accordance with our instructions for the purposes set out in this privacy statement;
  • to report or collect on debts owed to us;
  • customers via our publicly available customer-facing website, to enable customers to contact you, unless you have provided us with preferred alternative customer-facing contact details for your business that do not constitute personal data;
  • in case of a merger, acquisition or reorganisation with a purchaser of our company or all or substantially all of our assets;
  • to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions, where this is necessary to comply with these legal obligations;
  • to combat fraud or criminal activity, and to protect our rights or those of our affiliates, business partners and users, or as part of legal proceedings affecting our wider corporate group, as it is in our legitimate interests to prevent fraud and protect these rights;
  • in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts, to the extent this is necessary to comply with such legal obligations; or
  • in response to a request from lawyers representing customers engaged in a legal dispute with you, which arises from issues with a reward we have issued on your behalf, as it is in our legitimate interest to prevent any legal action being taken to compel us to disclose the data.

In a number of the cases set out above, we will transfer your personal data to a country located outside the United Kingdom which may not be considered as providing the same level of protection for personal data under the UK Data Protection Act 2018. In such cases, we put in place appropriate safeguards, including contractual commitments on recipients of the data, to ensure that there is adequate protection for your personal data. For more information about the safeguards in place and to view a copy of such safeguards, please contact us using the details below.

YOUR RIGHTS IN RELATION TO PERSONAL DATA; CONTACT US

In accordance with applicable law, you may (i) request access to any personal data we hold about you, (ii) request that it be updated, rectified, deleted or blocked, (iii) object to the further use of any personal data we hold about you, (iv) request that we restrict our processing of your personal data, and (v) request that we provide you or a third party with a copy of certain personal data about you (the right to ‘data portability’). If you have any questions or comments about our privacy practices or this Privacy Statement please contact our Data Protection officer at dpo@groupon.com or privacy@groupon.co.uk. For all other requests regarding your account, please contact your Giftcloud Business Consultant. You can also reach us via postal mail at the following address:

Invitation Digital Limited, First Floor, Merchants House North, Wapping Road, Bristol BS1 4RW.

We are committed to working with you to obtain a fair resolution of any request, complaint or concern about our use of your personal data. If, however, you believe that we have not been able to assist you, you have the right to make a complaint to the data protection authority in your country of residence.

RENTENTION OF PERSONAL DATA

We will retain your personal data for as long as your client account is active or as needed to provide you services. If you close your account, we will retain your personal data for a period where it is necessary to continue operating our business effectively, will maintain a record of your transactions for financial reporting purposes until these purposes no longer exist, and will retain it as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

PRIVACY PRACTICES OF THIRD PARTIES

This Privacy Statement only addresses the collection, processing and use (including disclosure) of information by us through your interaction with the Site. Other websites that may be accessible through links from the Site may have their own privacy statements and personal information collection, processing, use, and disclosure practices. Our business partners may also have their own privacy statements. We encourage you to familiarise yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.