Privacy Policy

GRUBBY LTD PRIVACY POLICYBACKGROUND:
Grubby Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our app and website and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Our communications are designed to tell you about the benefits we can offer, so that you have exclusive access to our best deals. We use information we have about you to tailor the content and try to ensure your Grubby experience is as relevant to you as possible.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested.

  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings: “Account” means an account required to access our app and website

  2. Information About Us

    Our app and website are owned and operated by Grubby Ltd, registered in England under company number 11402693

    Registered address:
    14 Borrowcop Lane, Lichfield, WS14 9DF
    Email address:
    help@getgrubby.co.uk
    Telephone number:
    03303201850
    Representative:
    Martin Holden-White

    We are regulated by Information Commissioner's Office under GDPR act 2018.

  3. What Does This Policy Cover?

    This Privacy Policy applies only to your use of our app and website. Our App and website may contain links to other websites.
    Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  4. What Is Personal Data?

    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  5. What Are My Rights?

    Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
    2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
    8. The right to data portability. This means that, if you have provided personal data us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
    9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

  6. What Data Do You Collect and How?

    Depending upon your use of our App and website, we may collect and hold some or all of the personal [and non-personal] data set out below, using the methods also set out in the table.

    • Identity Information including name, title, date of birth, genderVia app and website customer forms
    • Contact information including address, email, phone, name, surnameVia app and website customer forms
    • Business information including age, dietary preferences and feedback.Via app and website customer forms
    • Payment information including card details and bank account numbersVia app and website customer forms
    • Profile information including preferences and interestsVia app and website customer forms

  7. How Do You Use My Personal Data?

    Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so.

    What Data we Use Our Lawful Basis:
    Registering users on our app.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Providing and managing your Account.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Personalising and tailoring user experience.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Administering our App and website.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Managing payments
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Personalising and tailoring our products to you
    Any data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Communicating with you.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.
    Supplying you with information by email that you have opted-in-to.
    Any relevant data mentioned in point 6. To allow us to track users with them forming an account on our app and for us to tailor the user experience with the information we hold and connect with our users who opt in via email and phone communications.

    With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and post. You will not be sent any unlawful marketing or spam.
    We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
    If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.
    We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
    If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
    In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

  8. How Long Will You Keep My Personal Data?

    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Otherwise your personal data will be kept until such time as you opt out of communications with Grubby Ltd or you request to delete your user account and/or the data held with us.

  9. How and Where Do You Store or Transfer My Personal Data?

    We will only store or transfer your personal data store or transfer some of your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation.
    We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard is applied to such transfers:
    We only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

  10. Do You Share My Personal Data?

    In accordance with legitimate interest (where you have not opted-out), we may share your name and address (but never your email address or phone number) with other companies whose products or services may interest you. We do this by working with the following data providers or "co-operatives" who also help us to find new customers for our business:

    • We work with Epsilon Abacus (registered as Epsilon International UK Ltd), a company that manages the Abacus Alliance on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. They share information on what their customers buy. Epsilon Abacus analyses this pooled information to understand consumer’s wider buying patterns. From this information, retailers can tailor their communications, sending people suitable offers that should be of interest to them, based on what they like to buy.

    • Experian - Your personal data is shared with Experian Ltd for the purposes of managing a service called Club Canvasse, a home shopping and direct retailer data co-operative of which Grubby are members. By sharing information on what customers buy and pooling that with contributions from other members of the co-operative, the service allows Grubby to better understand our customers and to communicate with you more effectively. Please note, your personal information is not shared with any of the other members of the co-operative, and only aggregated data on the number and value of purchases is provided to members e.g. we will receive a report which states how many customers who have bought from us in the last 0-12mths, and who have also bought from other members of the co-operative in the last 0-12mths, or the last 24mths, last 36mths etc. To understand more please click through to experian.co.uk/cip to understand more about their marketing services.

    • I Behavior - To find new customers for our business we are a member of a large co-operative of like-minded UK retail brands that pool and share transactional information. We work with a program called IBehavior, part of the Company Conexance that processes customer transactional data on behalf of each Member. This process highlights spending patterns and allows us to identify suitable prospects to receive an offer or introduction from us via the post. Thus, we send postal offers and information only to prospective customers that are likely to be interested in buying from us. Co-op Member brands operate in numerous categories, including apparel, home and garden, collectables, food and wine, gadgets and gifts, entertainment, health and beauty, travel and leisure.

    Other trusted partners that we may share your data with where we think they offer a product or service that may be of interest to you, but are not limited to, one of the following categories:

    • Retailers e.g. other fashion and clothing, household, garden and general stores
    • Lifestyle and Charities e.g. leisure, holiday, travel, health and well being
    • Finance e.g. insurance, home, car, pet, pensions or personal
    • FMCG e.g. household goods
    • Utility e.g. gas, electric or water companies

    If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
    If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  11. How Can I Control My Personal Data?

    1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our App and website , you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
    2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

  12. Can I Withhold Information?

    You may access certain areas of our App and website without providing any personal data at all. However, to use all features and functions available on our App and website you may be required to submit or allow for the collection of certain data.

  13. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
    We will respond to your subject access request in not longer than one month of receiving it.

  14. How Do You Use Cookies?

    Our website may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of website.
    By using our website, you may also receive certain third-party Cookies on your computer or device.
    All Cookies used by and on our app and website are used in accordance with current Cookie Law.
    Before Cookies are placed on your computer or device, you will be shown you will be asked for your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our website may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
    In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our App and website more quickly and efficiently including, but not limited to, login and personalisation settings.
    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

  15. How Do I Contact You?

    16. To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Martin Holden-White:

    Email address:
    help@getgrubby.co.uk
    Telephone number:
    03303201850
    Postal Address:
    14 Borrowcop Lane, Lichfield, Staffs, WS14 9DF

  16. Changes to this Privacy Policy

    17. We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
    These terms and conditions were last updated on 20th August 2021