Privacy Policy

Welcome to the Gati Automata's privacy policy.

Gati Automata respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Table of contents

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Gati Automata collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our platform, including website, extension, newsletter or use or purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy 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 data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Gati Automata Limited is the controller and responsible for your personal data (collectively referred to as “Gati Automata”, "we", "us" or "our" in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Gati Automata Limited
Email address: privacy@shopper.com
Postal address: Innovation Birmingham Campus, Faraday Wharf, Holt Street, Birmingham, B7 4BB
Telephone number: 0044 1212505756

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 21st May 2019.

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

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data
Contact Data
Financial Data
Transaction Data
Technical Data
Profile Data
Usage Data
Marketing and Communications Data

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 website 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.

If you fail to provide personal data

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 data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions
Automated technologies or interactions
Third parties or publicly available sources

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your 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 below.

Purpose/ActivityType of dataLawful basis for processing
To register you as a new customer
  • (a) Identity
  • (b) Contact
Performance of a contract with you
To process and deliver your order including:
  • (a) Manage payments, fees and charges
  • (b) Collect and recover money owed to us
  • (a) Identity
  • (b) Contact
  • (c) Financial
  • (d) Transaction
  • (e) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
  • (a) Notifying you about changes to our terms or privacy policy
  • (b) Asking you to leave a review or take a survey
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary to comply with a legal obligation
  • (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Usage
  • (e) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To enable you to upload coupons, vouchers, discount codes or receive rewards
  • (a) Identity
  • (b) Contact
  • (c) Transaction Data
  • (d) Technical Data
  • (e) Profile
  • (f) Usage
  • (g) Marketing and Communications
  • (a) Performance of a contract with you
  • (b) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • (a) Identity
  • (b) Contact
  • (c) Technical
  • (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • (a) Identity
  • (b) Contact
  • (c) Profile
  • (d) Usage
  • (e) Marketing and Communications
  • (f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • (a) Identity
  • (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
  • (a) Identity
  • (b) Contact
  • (c) Technical
  • (d) Usage
  • (e) Profile
  • (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre on your accounts page where you can view and make certain decisions about your personal data use.

Promotional offers from us

We may use your Identity, Contact, Technical, 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).

You will receive marketing communications from us if you have requested information from us, joined our platform or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre on your accounts page where you can view and make certain decisions about your personal data use.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Specific third parties listed in the point 3. Third parties or publicly available sources.
  • 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.

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.

International transfers

As a global business we may store or process personal data within the European Economic Area (EEA) or outside the UK or EEA. We will always ensure that your personal data remains protected according to the standards outlined in this Privacy Policy. Where your personal data is transferred to a third party that is located outside the UK or EEA, we will implement contractual safeguards to ensure that your personal data maintains the protections outlined in this Privacy Policy. These safeguards include: ensuring that the recipient has agreed with us a data processing agreement and the EU model contract clauses; and when the recipient is in the US the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

We engage some international software services to help provide our web and mobile services. These providers include Amplitude Inc. and Segment.io Inc which are located in the United States. We have ensured that your personal data remains equally protected by these service providers by signing data processing agreements with them that are GDPR compliant. Amplitude itself also uses the subprocessors Amazon Web Services and Snowflake Computing Inc. Our agreement with Amplitude ensures that data may only be processed by Amplitude, Segment, and their subprocessors in compliance with GDPR protections.

Data security

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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for regulatory or tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@shopper.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties
External Third Parties
  • Service providers acting as processors based in the EEA who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Service providers located outside the UK or the EEA with whom we have a contractual relationship.
Your legal rights

You have the right to:

Request access
Request correction
Request erasure
Object to processing
Request restriction of processing
Request the transfer
Withdraw consent at any time