PRIVACY AND COOKIES POLICY

Who we are

We are Innov8 Creative Academy. A limited company based in Ireland. We have a number of products and website properties including this one. http://www.rainbowrewardsquad.com.

Privacy and cookies policy 22 March 2019

Your privacy and personal data is hugely important to us here at Innov8 Creative Academy. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better and more personalised experience.

OVERVIEW OF THIS NOTICE AND WHO WE ARE

What this Policy covers

This Privacy Notice sets out how Innov8 Creative Academy collects and processes your personal data as a customer. This principally relates to your use of our Site / App, whether you are using them to sign up to our newsletter, purchase a product or service, use a service, take part in a competition, or otherwise.

By visiting www.rainbowrewardsquad.com and our associated domains (our “Site”), and in particular by submitting your personal data to us, you are accepting and consenting to the practices described in this Notice. This Privacy Notice applies whether you are visiting our Site through an internet browser or through an “App” run by Innov8 Creative Academy on your device (an “App”).

It is important that you read this Privacy Notice together with any other privacy 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. This Privacy Notice supplements the other notices and is not intended to override them.

Who we are

The data controller is Innov8 Creative Academy Limited (referred to in this policy as “Innov8 Creative Academy”, “we”, “us” or “our”). Innov8 Creative Academy Limited is registered in Ireland under registration number 636195, with an address at Unit 22 Ace Enterprise Park, Bawnogue Road, Clondalkin, Dublin 22, Ireland.

Contact details

We welcome questions and comments regarding this Privacy Notice or our use of your data. If you would like to contact us please use the details below or any relevant links provided on our Site / App.

We have a Data Privacy Officer responsible for overseeing questions in relation to this Privacy Notice and our use of your data. Their details are set out below:

Email address: info@innov8academy.com

Postal address: Innov8 Creative Academy Limited, Unit 22 Ace Enterprise Park, Bawnogue Road, Clondalkin, Dublin 22, Ireland.

Privacy complaints procedure

You always have the right to make a complaint to the Data Protection Commissioner (“DPC”) if you think your data is being misused. The DPC is Ireland’s supervisory authority for data protection issues (www.dataprotection.ie).

We always appreciate the chance to try to deal with any data protection concerns before they are referred to the DPC so, if you are happy to do so, please do not hesitate to contact us using the details above so that we can try to help you out in the first instance.

Changes to this privacy notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. We recommend that you check this page from time to time to take notice of any changes we make, as they are binding on you if you provide us with information after such a change has been made.

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 using the details set out in the “Contact Details” section above.

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 where this is required or permitted by law.

Third party links

Our Site / App may contain links to and from 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. Please check the relevant third-party privacy policies before you submit any personal data to them.

Governing Law and Jurisdiction

This Privacy Notice is governed by Irish law and you can bring legal proceedings in respect of it in the courts of the Republic of Ireland.

THE DATA WE COLLECT ABOUT YOU

The data we collect about you

“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity of the person concerned has been removed (which is called “Anonymised Data”).

We may collect, use, store and transfer different kinds of personal data about you. This can be broken down into the following categories:

• Identity Data includes your name, username or similar identifier, marital status, title, date of birth and gender (this will primarily be text based, but could also include audio, photos, videos and other forms of media).
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes the internet protocol (IP) address of your device, details of the cookies on your device, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site / App.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, reviews, feedback and survey responses.
• Usage Data includes information about how you use our Site / App, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing communications from us and our third-parties and your communication preferences.
• We also collect, use and share “Aggregated Data”. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not reveal your identity. For example, we may aggregate our users’ Usage Data to calculate the percentage of those users accessing a specific Site / App 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 Notice.

We do not collect any “Special Category Data” about you. Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and information about your health, genetic or 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 inform you about our products or services). In this case, we may have to cancel a service you have with us (but we will notify you if this is the case at the time).

HOW WE COLLECT YOUR PERSONAL DATA

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

Direct interactions

You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes:

• Information that you provide by filling in forms on our Site / App:
• This includes information provided:
• at the time of registering to use our Site / App;
• when subscribing to a newsletter;
  • through a contact form (whether on our Site / App or by any other means);
• when posting material such as ratings and reviews;
• when requesting further services; or
• when searching for a product;
• Social Media: Information that you provide to us on our Social Media pages, such as Facebook, Twitter, Pinterest, Snapchat, Instagram and LinkedIn;
• App details: Information that you provide when you download or otherwise register on the App, use the App or share data via any social media functions on the App (which may include the phone number of the device used to use the App, your username and password on the App and other App registration information);
• Competition details: Information that you provide when you enter one of our competitions or participate in one of our promotions;
• Troubleshooting details: Information that you provide when you report a problem with our Site / App;
• Survey details: Information that you provide through surveys or when asked to give your opinions about our services and products;
• Contact details: Information that you provide when contacting our Customer Services Team or otherwise corresponding with us; and/or
• Transaction details: Details of transactions which you carry out with us and of the fulfilment of your orders (such as your financial details).
• Automated technologies or interactions

We may also collect and process the following data automatically when you use our Site / App:

• the internet protocol (IP) address of your device, your login information, details of the type of device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of your device’s wireless network interface, or the mobile phone number used by your device), mobile network information, your browser type and version, your time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site / App (including date and time), products you viewed or searched for, page response times, download errors and bugs, the length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the Site / App and any phone number used to call our customer service number;
• information stored on your device which you consent to share with us (such as contact information, friend lists, login information, photos, videos or other digital content) (you can typically turn off this functionality at any time by changing the relevant settings for the App on your device);
• any details of your current location which you consent to share with us (you can typically turn off this functionality at any time by turning off the ‘location services’ settings for the App on your device); and
• information provided to us by third-parties (including, for example, business partners, sub-contractors in technical, Wi-Fi, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies).
• Cookies

We may also receive Technical Data about you if you visit other websites employing our cookies, please see Section 6 (Cookies Policy) for further details.

Third parties or publicly available sources

We may receive Anonymised Data and/or Aggregated Data from various third-parties and public sources such as those set out below:

data from analytics providers, advertising networks (such as Google AdWords / Google Shopping) and search information providers (all of which may be based outside the EU); and

contact, Financial and Transaction Data from providers of technical, payment and delivery services (which may be based outside the EU).

HOW WE USE YOUR PERSONAL DATA – GENERAL SITE

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

we need to perform the contract we are about to enter into or have entered into with you;

it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests;

we need to comply with a legal or regulatory obligation; and/or

you have specifically consented to us using your personal data in a particular way.

Please 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;

combine information from other sources with information you give to us and that which we collect about you;

HOW WE USE YOUR PERSONAL DATA – SPECIAL PURPOSES

How we use your data – Special Purposes

We may occasionally require your personal data for additional Special Purposes, such as promotions connected with events and programs. You may have been linked to this portion of this Privacy Notice from another website or app relating to one of these special purposes.

Please note that the rest of this Privacy Notice (whether it is regarding who we are, how to contact us, our complaints procedures or otherwise) will still apply to our handling of your data for these Special Purposes. In the event that there is a conflict between this “Special Purposes” section and the wider Privacy Notice, this “Special Purposes” section will apply.

COOKIES POLICY

What are cookies

Cookies are small pieces of information that are stored on the hard drive of your device and they enable a server to collect information from an internet browser. You can find out more about how cookies work at www.aboutcookies.org.

How we use cookies

We use cookies to:

• personalise our Site / App to you. For example, to try and ensure that language and region displays are correctly configured for you;
• allow you to use our Site / App in a way that makes your browsing experience more convenient;
• place advertisements for our products / services on: (a) our Site / App; and (b) other sites / apps involved in advertising or partnership networks in which we participate;
• personalise the advertisements which we place to you;
• improve our Site / App. For example, knowing how our users navigate our Site / App and use its features allows us to streamline the user experience, speed up searches, identify bugs, make enhancements and ultimately get you to the right page and product faster;
• review the popularity of our products and advertisements with reference to platform, location and other related factors;
• estimate our audience size and usage pattern;
• provide faster and more personal service by collecting information in respect of any accounts which you have on our Site / App;
• collect Anonymised Data about the websites from which users have travelled to our Site / App;
• store information about any preferences which you set, so we can do things like greet you personally and speed up your log-in when you come back to our Site / App;
• identify which of your device(s) you use to access our Site / App or any account which you have registered on it; and
• prevent credit fraud and various forms of cyber-crime.

The cookies we use:

• may persist on your device between visits to our Site / App, so that, for example, we can identify you when you visit again; and
• may be provided either by us or by third-party service providers (such as analytics and search engine providers).

Avoiding cookies

You can set your browser to accept or reject certain cookies or, if you prefer, you can set your browser to alert you each time a cookie is detected. Previous cookies that have been stored on your device can also be deleted. However, if you block our cookies or you subsequently delete a cookie that has been placed on your device, it will not be possible for you to use our Site / App effectively as our systems rely on cookies to identify you as the user.

DISCLOSURES OF YOUR PERSONAL DATA

First and foremost, you can rest assured that your personal data will not be shared with third-parties unnecessarily. We may disclose your personal data for the purposes set out in this Privacy Notice:

• if the possibility of such disclosure is otherwise stated in this Privacy Notice, our Terms of Use, our Terms and Conditions of Sale or otherwise when the personal data is collected from you;
• in particular, to the specific third-parties described in the tables in Section 4 (How we use your personal data – General Website) and Section 5 (How we use your personal data – Special Purposes)
• to service providers acting as processors or joint controllers who provide us with IT and system administration services;
• to professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services;
• to the office of the Revenue Commissioners, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect our rights, property, or safety, or the rights, property or safety of our customers, or others. This includes exchanging information with: (a) the police or other investigatory or law enforcement authorities; and (b) companies and organisations involved in fraud protection and credit risk reduction;
• and/or
• to 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 Notice.
• We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. Unless specifically stated in this Privacy Notice, 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.

Disclosure of Anonymised Data or Aggregated Data

We may also share Anonymised Data or Aggregated Data to third-parties such as:

• our advertisers; and
• analytics and search engine providers that assist us in the improvement and optimisation of our Site / App. This Anonymised Data will be collected using cookies in a way which alone cannot identify any individual.
• Third party marketing

We will never share your personal data with any other company (as defined above) for marketing purposes not related to Innov8 Creative Academy.

INTERNATIONAL TRANSFERS

International Transfers

The data that we collect from you will be stored on secure servers within the European Economic Area (“EEA”). The majority of such data is held in Ireland.

Certain information may be accessed and processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services (such as content moderation or the maintenance of our data storage facilities).

If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• the transfer will be to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission;
• we will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
• or
• where we use providers based in the US, we may transfer data to them if they are part of the “Privacy Shield” scheme. This scheme requires them to provide similar protection to personal data shared between the Europe and the USA.

DATA SECURITY

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 particular we use ‘Transport Layer Security’ (“TLS”) technology. TLS technology helps prevent you from inadvertently revealing personal details using an unsecured connection.

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.

Please note that, notwithstanding the steps we take, the transmission of information via the internet can never be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site / App.

DATA RETENTION

Data Retention

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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 tax purposes. We typically retain this information for a further six to twelve months to ensure that no relevant claim has been made within that six-year period before we dispose of it.

In some circumstances we may 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

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us using the details set out in the “Contact Details” section in Section 1 (Overview of this policy and who we are). A summary of the rights you have is set out below:

• Opting-out of Marketing: You can ask us or third-parties to stop sending you marketing communications at any time by: (a) visiting our unsubscribe page on our website or App and following the instructions provided; (b) by using the “unsubscribe” link at the bottom of any marketing communications which we send to you; or © by contacting us at any time using the details set out in the “Contact Details” section in Section 1 (Overview of this policy and who we are).
• Data Subject Access Requests: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Correction: You have the right to 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, though we may need to verify the accuracy of the new data you provide to us.
• Erasure: You have the right to request we erase 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. Please 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.
• Processing Objection: You have the right to object to us processing 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Processing Restriction: You have the right to request we restrict the 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; © 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.
• Data Transfer: You have the right to request we transfer 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.
• Withdrawing consent: You have the right to withdraw your consent to processing where we are relying on that 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.
• 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.

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 may 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.