1. INTRODUCTION
1.1. Fast Refund Co Ltd, a company incorporated and registered in England and Wales under company number 13751491 whose registered office is at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ (“At Last”, “we”, “us” and “our”), publishes the platform accessible via our own website www.atlast.co, accessible directly or via the websites of our partners (being, along with any other website or application for web or smart devices published by At Last from time to time, the “Platform”).
1.2. At Last respects your privacy and is committed to protecting your personal data. This Privacy Policy will explain how we look after your personal data when you visit the Platform (regardless of where you visit it from) as either a Customer or a Merchant and tell you about your privacy rights and how the law protects you (the “Privacy Policy”).
1.3. This Privacy Policy should be read alongside, and in addition to, our Merchant Terms and Conditions, Customer Terms and Conditions and Cookie Policy (the “Terms”) as applicable.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Policy
2.1. This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Platform where you are a customer (“Customer”) or merchant (“Merchant”) and register an account with us (“Account”), including any personal data you may provide through the Platform when you sign up to our newsletter, manage or issue returns (“Returns”), request or issue refunds (“Refunds”) and otherwise use our services.
2.2. The Platform is not intended for children, and we do not knowingly collect personal data relating to children.
2.3. It is important that you read this Privacy Policy together with any other policies 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 personal data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Controller
2.4. At Last is the data controller and responsible for personal data collected by us when you interact with and use the Platform, including the creation of an Account when you first agree to use our services.
2.5. If you are a Customer and you provide personal data to a Merchant on their website or platform, the Merchant is the data controller in respect of such personal data and their use of your personal data is governed by the Merchant’s privacy policy.
2.6. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact At Last using the details set out below.
Contact details
2.7. If you have any questions about this Privacy Policy or our privacy practices, please contact At Last. Our full details are:
Full name of legal entity: Fast Refund Co Ltd
Name or title of data privacy manager: Roberto Sousa
Email address: support@atlast.co
2.8. 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 chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
2.9. 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
2.10. The Platform may include links to third-party websites, plug-ins and applications including without limitation those of Merchants. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
3. THE DATA WE COLLECT ABOUT YOU
3.1 Personal data, (also referred to as 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).
3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes title, first name, maiden name and last name.
(b) Contact Data includes billing address, home address, email address and telephone numbers.
(c) Transaction Data includes details of any payments to and from Merchants and other details of services Merchants have purchased from us.
(d) Order Data includes details about payments due to and from Customers and Merchants and other details of products and services purchased by Customers from Merchants (“Orders”).
(e) Device Data includes the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), your internet protocol (“IP”) address, browser type and version, mobile network information, your mobile operating systems, referral source/exit pages, length of visit, page views, Platform navigation and search terms that you use and time zone setting.
(f). User Profile Data includes your username and password, Orders and Refunds made by Customers, your feedback and survey responses and photographs used to enrich return information or used as a digital avatar for your At Last account.
(g) Usage Data includes details of your use of any of our Platform or your visits to the Platform including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes (where you are a Merchant) or otherwise, and the resources that you access.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
(i) Location Data includes your current location disclosed by GPS technology.
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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. 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 collect any “Special Categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
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 personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to terminate the Terms we have in place with you.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
4.1. We use different methods to collect data from and about you including through:
(a) Direct interactions. This is information (including Identity, Contact, Financial and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Platform or by corresponding with us by email or other contact form provided on the Platform. This includes personal data you provide when you:
(i) create an Account on the Platform;
(ii) purchase and use any of our services;
(iii) manage Refunds;
(iv) participate in or grant a Reward via the Platform;
(v) request relevant marketing to be sent to you;
(vi) opt in to email updates and/or to receiving push notifications;
(vii) enter a competition, promotion or survey ran by At Last; or
(viii) give us feedback or contact us.
(b) Automated technologies or interactions. As you interact with the Platform, we will automatically collect Content and Usage Data. We collect this data by using Intercom customer support platform. We collect this data by using cookies, server logs and other similar technologies. We may also receive Device Data about you if you visit other websites employing our Cookies. Please see our Cookie Policy for further details.
(c) Third parties or publicly available sources. We will receive personal data about you from various third parties, public sources and technologies as set out below:
(i) Device Data from the following parties:
(a) analytics providers including but not limited to Google and Amazon Web Services development suite based inside and outside the UK;
(b) any other affiliate partners we are working with; and
(c) search information providers based inside and outside the UK.
(ii) Order Data from Merchants via Shopify or any relevant internal order management systems based inside and outside the UK;
(iii) Contact, Financial and Transaction Data from providers of technical and payment services including Stripe; and
(iv) Identity, Contact, Order, Device and Profile Data from our chatbot provider, Intercom (as further set out below).
How we use your personal data
4.2. We will only use your personal data when the law allows us to and most commonly, in the following circumstances:
(a) where you have consented before the processing;
(b) where we need to perform a contract we are about to enter or have entered with you;
(c) 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; or
(d) where there is a legal requirement for us to comply with.
4.3. Generally, we do not rely on consent as a legal basis for processing your personal data.
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
5.1. We may process your personal data for more than one of the following lawful grounds, depending on the specific purpose for which we are using your personal 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 attached in the Appendix A.
6. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
7. PROMOTIONAL OFFERS FROM US
7.1. We may use your Identity, Contact, Device, Order, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you - we call this marketing.
7.2. You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
8. THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
8.1. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
8.2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of arranging a Return.
9. COOKIES
9.1. We use cookies and/or other tracking technologies to distinguish you from other users of the Platform and to remember your preferences. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, please see our Cookie Policy.
9.2. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.
10. HOW YOU CAN WITHDRAW CONSENT
Where you have indicated your consent to processing and the use of Location Data upon using the Platform for the first time, you may change your mind and withdraw consent at any time by contacting us by email at support@atlast.co but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
11. CHANGE OF PURPOSE
11.1. 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 we plan to do this, we will let you know in advance by either contacting you or by updating this privacy policy.
11.2. If we need to use your personal data for an unrelated purpose, we will always obtain your consent before we do so.
11.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules and where this is required or permitted by law.
12. DISCLOSURES OF YOUR PERSONAL DATA
12.1. We may share your personal data with the parties set out below for the purposes set out in the table above.
(a) Amazon Web Services or Google Analytics who provide IT and system administration services to us and require access to personal data to do so; or
(b) Amazon Web Services or Google Analytics to whom we provide services including, without limitation, to Merchants where you are a Customer; or
(c) R&D Unlimited Company (trading as ‘Intercom’) acting as data processor on our behalf which provides the chatbot services accessible on our Platform (please see Intercom’s privacy policy which explains how Intercom uses the data of end-users of its chatbot - https://www.intercom.com/legal/privacy# ); or
(d) HMRC Revenue & Customs, regulators and other authorities acting who may require reporting of processing activities in certain circumstances.
12.2. We may also share your personal data with 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.
12.3. 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.
13. DATA SECURITY
13.1. 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.
13.2. We have put in place procedures to deal with any suspected breach of your personal data and will notify you and any applicable regulator of a breach where we are legally required to do so.
14. DATA RETENTION
How long will we use your personal data for?
14.1. We will only retain your personal data for as long as you hold an account with us, and will remove your personal details within 1 month of you requesting closure of your Account. 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.*
14.2. If your Account is not used for a period of 3 years, after that time we will erase your personal details.*
14.3. We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Platform and/or the purpose, or we are legally obligated to retain this data for longer time periods.*
15. YOUR LEGAL RIGHTS
15.1. Under certain circumstances, you have rights under data protection legislations in relation to your personal data. These rights include:
(a) Right to access - the right to request copies of the personal data we hold about you at any time. If we provide you with access to the personal data we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
(b) Right to correct - the right to have your personal data rectified if it is inaccurate or incomplete. 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.
(c) Right to erase (“Erasure Request”) - 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 the Data Protection Legislation. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Right to restrict our use of your personal data - this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
(e) Right to data portability - the right to 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your personal data.
(f) Right to object - the right to object to our use 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.
(g) Withdraw consent – the right to 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.
15.2. 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.
15.3. We try to respond to all legitimate requests within one (1) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a request for large quantities of information.
Appendix A.
