Privacy and Cookie Policy

We take your privacy and using your personal data very seriously. This policy covers how we collect personal data, what we do with it and who we share it with.  It also tells you about your privacy rights and how the law protects you. It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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.


Controller

GVS Group is made up of different legal entities. This privacy policy is issued on behalf of the GVS Group so when we mention “GVS”, “we”, “us” or “our” in this privacy policy we are referring to the relevant company in the GVS Group responsible for processing your data.

GVS Prepaid Ltd will be the controller of the personal data you provide to us for the One4all Gift Card and Reward Card. GVS Prepaid Ltd is a UK registered company (number 09193070) and registered with the UK’s Information Commissioner's Office (ICO) with reference ZA084661.

GVS Gift Voucher Shop DAC will be the controller of the personal data you provide to us for the Bikes4work scheme and the Christmas Club (up until the point funds are converted into Gift Cards, where GVS Prepaid Ltd will be the controller). GVS Gift Voucher Shop DAC is a designated activity company registered in Ireland (number 348932)

Contact Details

You can contact us at:

 

Data Controller

Data Controller

Full name of legal entity:

GVS Prepaid Limited.

GVS Gift Voucher Shop DAC

Name or title:

Compliance Manager

Compliance Manager

Email address:

dpo@gvsprepaid.com

dpo@gvsprepaid.com

Postal address:

30 St John’s Lane, London, EC1M 4NB

PO Box 8942, Malahide Co Dublin

Telephone number

0207 608 6299

01 870 8100

Changes to this Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on our website and, where appropriate and possible, you will be notified through your online account or by e-mail.

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.


Personal Data we collect about you

By “your data”, “your personal data”, and “your information” we mean any information about you, which you or third parties provide to us. which is capable of identifying you.  We also sometimes refer to “processing”.  This means any operation we perform on such data or information, such as collection, organising, storing, updating, using, disclosing and erasing.

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

  • Identity Data includes fist name, last name, title, date of birth, employee identification number, the number of your passport, driving licence or other ID;
  • Contact Data includes address, email address and telephone (including mobile) numbers;
  • Financial Data means your bank account and payment card details;
  • Transaction Data means the details about payments to and from you and other details of products and services you have purchased from us, including transactions carried out with One4all Gift Cards and Reward Cards.
  • Technical Data includes Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, geo-location, browser plug-in types and versions, operating system (OS) and platform when you access our websites;
  • Usage Data includes [the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages.
  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].]

We also collect aggregated data such as statistical or demographic data. This may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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.

How we collect your personal data?

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

- Direct Interactions: you or other person using our website (for example, someone who wishes to order a gift card for you) may give us identity data, contact data, financial data and profile data by entering the information on our website or give us in any other way, such as by communicating with us by post, email or telephone. This includes personal data provided when:

  • you apply for our products or services (including where you order gift cards for third party beneficiaries);
  • create an account on our website;
  • respond to a questionnaire or survey;
  • give us some feedback or contact or interact with us to request support.

- Automatic Information: we may receive and automatically collect certain types of information whenever you interact with our website. This may include information about your electronic devices, browsing actions and patterns when you access our website or advertisements and other content served by or on behalf of us on other websites. We collect this information by using "cookies" and other similar technologies.

- Third Parties or publicly available sources: we may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google;
  • Contact and Financial Data from the providers of technical and payment services;
  • Identity and Contact Data from a third party, such as your employer or other company which has enrolled you to their rewards scheme;
  • Identity and Contact Data from credit reference agencies, other electronic identity verification service providers and other publicly availably sources such as Companies House and the Electoral Register.

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 have entered into with you or the person who has ordered the card for you;
  • where we need to comply with a legal or regulatory obligation; or
  • where it is necessary for our legitimate interests and only if your interests and rights do not override those interests.

Purposes and legal bases for which we use your personal data

We have set out below, in a table format, a description of the purposes of our processing of 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 on more than one legal basis depending on the specific purpose for which we are processing your data.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Register/set-up our customer record, including completing and processing card orders and delivering gift cards to card recipients.

  • Identity
  • Contact
  • Financial
  • [Profile]
  • Performance of a contract with you, the person who ordered the cards for you (including employer or other entity which has enrolled you in their rewards programme) or taking steps to enter into such a contract at your request.
 

Confirm and verify your identity

  • Identity
  • Contact
  • Financial
  • Necessary to comply with a legal obligation;
  • Necessary for our legitimate interests (to prevent our products being used for fraud or other financial crime).
 

Provide you with the products and services that you request or receive from, or via us, so that we can:

  • provide you with gift and rewards cards (including any replacement cards);
  • manage the operation of your account;
  • process transactions carried out with the cards you receive from us and any redemption requests;
  • manage and process fees and charges;
  • collect and recover money owed to us.
  • Identity
  • Contact
  • Financial
  • Transaction
  • Performance of contract with you (or the employer or other entity which has enrolled you in their rewards programme);
  • Necessary to comply with a legal obligation;
  • Necessary for our legitimate interests (to recover fees/debts due to us)
   

To manage our relationship with you, including:

  • Notify you about changes to our terms, services or privacy policy
  • Contacting you if there is any action you need to take to be able to continue using our products and services;
  • Responding to your queries and requests;
  • To notify you around the anniversary of an order that you previously placed that you may want to repeat the order;
  • Ask you to leave a review or take a survey.
  • Identity
  • Contact
  • Transaction
  • Profile
    • Performance of a contract with you
    • Necessary to comply with a legal obligation
    • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and to keep our customers satisfied and to develop our business)
   

To administer and protect our business and this website (including troubleshooting, data analysis, testing, research.)

  • Identity
  • Contact
  • Technical
  • Necessary for our legitimate interest (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)
  • Necessary to comply with a legal obligation
 

To deliver relevant website content in the most effective manner for devices (phone, computer, tablet)

  • Identity
  • Contact
  • Profile
  • Usage
  • 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)
 

Where we need you to provide personal data by law, or under the terms of a contract we have with you or in order to enter into a contract we will inform you. If 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 gift cards). In this case, we may have to cancel a product or service you have with us or third parties have requested to provide you, but we will notify you if this is the case at the time, to the extent we are able to.


Direct Marketing

GVS, from time to time, may wish to contact you about offers or products that are relevant to you.  You may receive marketing communications from us if you have given us permission.  Where you give permission we may contact you by e-mail, mail, telephone, SMS or other means (as permitted by your consent).

Third Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside the GVS group of companies for marketing purposes.


Withdrawal of consent (Opting Out)

You can at any time withdraw your consent to direct marketing by:

- Clicking on the unsubscribe option on any emails you receive

- Contacting us via phone, post or email using the email address chealy@one4all.ie with ‘Unsubscribe’ in the subject line

Whilst this will stop GVS from mailing you, if you’ve shared your personal data with a third party (such as our retailer of month promotion) unsubscribing from GVS mailings will not stop the third party from mailing you.  You will still need to unsubscribe from the third party(ies) (if you so wish) in accordance with their unsubscribe procedures.

How long will we keep personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We will hold your data for no more than 6 years following the termination of our relationship with you. The period will be determined by the types of products and services you have purchased from us.  

By law we have to keep basic information about you (including Contact, Identity, Financial and Transaction Data) for 5 years after our business relationship with you ends for anti-money laundering purposes.

We will retain information about you after you have terminated your use of our services, or if your account becomes dormant, for as long as permitted or required for legal, regulatory, fraud and other financial crime prevention purposes and for lawful permitted business purposes.

Receipients to whom we may disclosure your Personal Data

In order to fulfil the purposes for processing your personal data, as set out above, we may need to share your personal data for the purposes set out above (see Purposes and legal bases for which we use your personal data).

We will share your personal data with other companies in the GVS group of companies (which includes our subsidiaries, our ultimate holding company and its subsidiaries) who provide (or procure the provision of) the card delivery and customer contact centre services, IT, system administration. All GVS group companies are obliged to respect the confidentiality of this personal information.

We may also share your personal data with selected third parties, including:

  • your employer or other entity that has enrolled you into their rewards programme for the performance of any contract we have entered into with them and/or the performance of our contract with you (for example, to deliver cards to you);
  • with technical payments processor to enable payments authorisation;
  • card production and delivery vendors to enable delivery of cards to you/intended recipient;
  • Customer contact centre, for when you call into us to discuss your card
  • electronic identity verification, credit referencing agencies and sanctions screening service providers.

Where we disclosure personal data to such third parties we do so under a contract which includes requirements for the third party to have adequate security measures in place, only use the personal data for the purposes it was provided for and to delete or return it once no longer needed.

We may also disclose personal information to third parties under the following circumstances:

  • If GVS (or its group company) sells, buys, transfers or merges in whole or in part business or assets, in which case personal data held by us about customers may be one of the transferred assets;

If we are under a legal duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions of our products and other agreements; or to protect the rights, property, or safety of GVS, our customers, or others. This includes exchanging information with other companies and organisations, such as law enforcement departments, regulators, government departments (e.g. Revenue, HMRC), for the purposes of fraud protection, anti-money laundering and credit risk reduction.


International Transfers

The majority of our third-party processors are based in the European Economic Area (EEA) however, when your personal data is transferred outside the EEA for further processing by the recipients described above, we ensure at least one of the following safeguards is implemented:

  • we will only transfer the personal data to a country which is deemed by the European Commission to provide an adequate level of protection for personal data;
  • where we transfer the data to third parties, we will use specific contracts between us and the recipient in a form approved by the European Commission to protect it;
  • where the transfer is to the USA, the recipient is within the EU-US Privacy Shield.

Data Security

We take all steps reasonably necessary to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Our site has security measures in place to protect the loss, misuse and alteration of the information under our control. Our secure server software (SSL) is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your personal information, including credit card number, name, and address, so that it cannot be read as the information travels over the Internet.

 

All parties with access to your personal data are all subject to a strict duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the UK Information Commissioner’s Office (ICO) (where GVS Prepaid is the data controller) or The Irish Office of the Data Protection Commissioner (DPC) (where GVS Gift Voucher Shop DAC is the data controller) of a breach where we are legally required to do so.


Your rights

Under the General Data Protection Regulation (GDPR), you, as a data subject have a number of rights which are detailed below:

  • Request access to your personal data (commonly known as "data subject access request"). This enables you to receive a copy of the personal data we hold about you or are otherwise processing.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. We will need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. 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 local law. 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.
  • Object to processing 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.
  • Request restriction of processing 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 data is unlawful but you do not want us to erase it; (c) where you need us to hold the 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 data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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.
  • 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.

If you wish to exercise any of the rights set out above, please write to Compliance Manager, One4all, PO Box 8942, Malahide, Co Dublin.

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 may refuse to comply with your request in these circumstances.

Your right to complain

Where GVS Prepaid Ltd is the controller, 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).

Where GVS Gift Voucher Shop DAC is the controller, you have a right to complain to the Ireland’s Office of the Data Protection Commissioner (DPC) (https://www.dataprotection.ie/docs/Home/4.htm)

We would, however, appreciate the chance to deal with your concerns before you approach the ICO or DPC so please contact us in the first instance.


Your right to complain

A 'cookie' is a small piece of information that many web sites use to help make shopping online easier. Information is stored on your computer's hard drive (in your browsers temporary internet files folder).

Our Website uses and stores this type of information, as with that obtained from other cookies used on the site, to help it improve the services to its users. Our Website does not store personally identifiable information in your cookie in order to minimise any security risk.

When you visit this site, your cookie helps us keep track of your shopping cart contents. If you choose to buy from us, your cookie allows us to recognise you and the contents of your shopping cart.

We use an independent measurement and research company to gather data regarding the visitors to this web site using cookies and code which is embedded in the site. Both the cookies and the embedded code provide statistical information about visits to pages on the site, the duration of individual page view, paths taken by visitors through the site, data on visitors' screen settings and other general information. This data is for GVS use only.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.


List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE name

COOKIE Description

CART

The association with your shopping cart.

CATEGORY_INFO

Stores the category info on the page that allows to display pages more quickly.

CUSTOMER

An encrypted version of your customer id with the store.

CUSTOMER_AUTH

An indicator if you are currently logged into the store.

CUSTOMER_INFO

An encrypted version of the customer group you belong to.

CUSTOMER_SEGMENT_IDS

Stores the Customer Segment ID

EXTERNAL_NO_CACHE

A flag, which indicates whether caching is disabled or not.

FRONTEND

You session ID on the server.

GUEST-VIEW

Allows guests to edit their orders.

LAST_CATEGORY

The last category you visited.

LAST_PRODUCT

The most recent product you have viewed.

NO_CACHE

Indicates whether it is allowed to use cache.

PERSISTENT_SHOPPING_CART

A link to information about your cart and viewing history if you have asked the site.

RECENTLYCOMPARED

The items that you have recently compared.

STF

Information on products you have emailed to friends.

STORE

The store view or language you have selected.

USER_ALLOWED_SAVE_COOKIE

Indicates whether a customer allowed to use cookies.

VIEWED_PRODUCT_IDS

The products that you have recently viewed.

 

 

GVS Gift Voucher Shop Ltd. Trading as The Gift Voucher Shop, Registered in England No. 04286835. Registered Office, 4 The Merlin Centre, Acrewood Way, St Albans, Herts, AL4 0JY. © 2018 The Gift Voucher Shop - One4all Gift Cards. One4all Gift Vouchers