Revised 7 April 2020
1. Emails and mobile push notifications from Ailuna
You are probably most interested in how we will use your email address and mobile device ID to communicate with you. Here is our promise:
Service emails and mobile push notifications (“Service Messages”). There are emails and push notifications we will need to send you to provide you with a good Ailuna service.
A list of the types of emails and mobile push notifications you will receive to help you use the service most effectively (which we call Service Messages), include the following:
Welcome emails – welcome e-mail containing a link to verify your e-mail.
Key service messages – if we need to notify you about changes to the service.
Notifications necessary for our sustainability and behavioural change programs to work, including tips & tricks
Useful sustainability and environmental news and information
New friend notifications – when you have friend invitations pending or accepted friend invitations
Social community & content updates – for example when friends and other Ailuna Users post new content or comment on yours
Service suspension notices – if you break our rules around acceptable content (images, video and text)
Other Ailuna relevant emails and notifications
Newsletters. When registering, you are given the option to receive our occasional newsletters. We use these to notify you about new features, ask your opinion about the mobile app and website. We only send a newsletter when there is something worthwhile to tell you about or if we need your feedback to improve our service.
Generally you’ll get a newsletter about once every month. If you decide you no longer want to receive these newsletters – or if you aren’t currently receiving them and want to – all you need to do is change your email preferences.
2. The information we gather and track
We always aim to gather only the information we need in order to provide you with a functional, compelling and relevant service designed to help Users adopt and maintain more sustainable lifestyles as well as educate them and keep them informed about associated news and events.
We collect both Personal Data and Other Information in support of these efforts.
“Personal Data” is information that can be used, directly or indirectly, alone or together with other information, to identify you as an individual User. This may include your precise Location Data.
The submission of your Personal Data to us is voluntary in order to be able to use Ailuna. The consequence of not submitting Personal Data may be that you cannot use Ailuna or functionality will be limited or broken.
“Other Information” is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity. Some examples include age, gender, browser and operating system, time spent using our Services, and webpages visited. We collect and use this information to understand how you and our Users as a whole use our Services and constantly tune, enhance, innovate and build products and services to reflect the needs of our Users.
We collect Personal Data in the following ways:
1. When you register with Ailuna, you provide your first name, last name and your email address, password, as well as city, county/state and country. We may also ask you to provide your mobile phone number.
Additionally, we encourage you to indicate which sustainability choices you have made, which will help us provide a better and more relevant service to our Users, and for Users to seek relevant advice and guidance from other Users with experience in the topics they are interested in.
All such information fields are available to you, and capable of being changed, through the My Ailuna page, as well as you can control which information is kept private vs. shared.
We process this Personal Data because it is necessary for performing the agreement with you for the use of Ailuna, pursuant to GDPR article 6 (1) (b).
2. When you use or interact with our Services, we collect Personal Data such as Location Data. We may use your Location Data to provide a more relevant service. This includes showing you a map or list view of nearby 2nd hand, charity, refill or other sustainability stores, groups and events and suggesting the most relevant stores, groups and events for you.
We may also use your Location Data to conduct analytics to improve Ailuna.
We collect Location Data in several ways:
· from your wireless carrier,
· directly from the device on which you use our Services.
The way in which we collect Location Data is different depending on whether you are accessing Ailuna through a mobile app and website or a mobile application.
If you are accessing Ailuna through our mobile app, the way we collect Location Data will differ depending on your mobile device’s operating system. In all events, we do not collect Location Data, unless you have allowed its collection when prompted. If you decline to allow Location Data collection in the app, we will not collect your Location Data unless you manually enter it in.
We process this Personal Data based on your consent, pursuant to GDPR article 6 (1) (a).
3. When you take surveys and/or enter contests, we may collect contact, demographic and eligibility information.
We may sponsor contests and other promotions (“Promotions”) and we may request that you provide Personal Data, such as name, address, email address, telephone number and age and other information that may be appropriate in order to participate.
We may also launch surveys that ask you to answer questions about a range of topics from personal information to behaviour, sustainability, brand and product preferences.
We process this Personal Data based on your consent, pursuant to GDPR article 6 (1) (a) or because it is necessary for the purposes of the legitimate interests pursued by us in order to improve our Platform, pursuant to GDPR article 6 (1) (f).
4. When you create, upload and share content, or other Users create, upload and share content about you.
Information you choose to share: Content created / uploaded by you on the mobile app and website, which may include uploading personal information in the My Ailuna section or uploading photos, videos, comments, stories, tips & tricks.
Information other Users share about you: We may also receive information from other Users, such as when they upload content relating to you or post comments in relation to your uploaded content.
We also collect responses from trusted Payment Service Providers when you make purchases on Ailuna. Depending on payment method, this may include a subscription ID that is sent to the Payment Service Provider. We DO NOT collect any credit card information.
When you are using a mobile device, we also collect and use your Apple Identifier for Advertising (IDFA) and Google Advertising ID (AAID) to recognize your device and support activities on our Services. These number values are not permanently tied to your device and, depending on your operating system, you can reset it through your device settings.
When you upload a photo or a video we may also receive additional information through metadata about where that photo was taken or the video recorded, such as the time, date and location.
We may also receive statistical information that does not personally identify you from our advertising partners who work with us to deliver more relevant, higher quality advertising to you on the mobile app and website and to understand online activity.
We process this Personal Data because it is necessary for the purposes of the legitimate interests pursued by us in order to improve our Platform, pursuant to GDPR article 6 (1) (f).
Sharing with other websites and applications.
You may choose to enable, log into or sign on to Ailuna through Facebook or other social media platforms such as Instagram, Google and Apple (“Social Networking Services”). When you connect using your Social Networking Services accounts, we may collect Personal Data that you have provided to that Social Networking Service.
If you do not want to provide us with this information, you will need to amend the privacy settings on your Social Networking Services account. For more information, please review the privacy disclosures and terms of your Social Networking Services account, which govern how that account information is collected and shared with us.
We process this Personal Data based on your consent, pursuant to GDPR article 6 (1) (a).
Cookies. We use small text files known as “cookies” to enhance your experience of our service as follows:
To hold your login information (mentioned above), so that you do not need to log in each time you visit the mobile app and website, and your homepage is personalised. This option can be turned off by logging out.
To facilitate optimal use of our service by means of a temporary “session” cookie which helps you to navigate through the mobile app and website and enhances your user experience. These cookies disappear when your browser session ends, or when you click the “Signout” link on the mobile app and website homepage; and
To help us recognise you as a unique visitor by means of a “persistent” cookie when you return to our mobile app and website and to allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts and messages repeatedly.
Analytical cookies. We also use analytical cookies and similar analytical tools to compile anonymous, aggregated statistics that allow us to understand how Users use our service and to help us improve the structure of our mobile app and website. This is not personal data, and we cannot identify you in this way. These cookies allow us to understand who has seen which pages, to determine how frequently particular pages to determine the most popular areas of the mobile app and website, and generally to monitor usage of the mobile app and website. We will also use aggregate non-personal data to track the success of any advertising campaigns on our mobile app and website, to improve the effectiveness and suitability of advertising in communications sent by us and other companies in the Ailuna group and/or to provide to third parties anonymised, demographic data provided by you to target advertising more appropriately. We do not provide our advertising partners with information that identifies you as an individual.
Further information. Please contact our customer support service to request further details about individual cookies used on our mobile app and website by us and by third parties.
Disabling cookies. Most internet browsers are automatically set up to accept cookies, but you can set your browser to refuse a cookie by changing your browser security settings, or you can ask your browser to show you where a cookie has been set up. You may also be asked to consent to the use of certain cookies upon entering or registering on our mobile app and website. Certain features on our mobile app and website are only activated by the presence of a cookie so, if you do not accept certain cookies, our mobile app and website will not work properly. You can find out more on how to disable/enable cookies via the following link www.allaboutcookies.org.
3. Sharing and use of information
Managing the mobile app and website (including your account)
We may use your Personal Data to respond to your requests for technical support or to any other communication you initiate. This includes accessing your account to address technical support requests.
Providing advanced mobile app and website features to you
Suggesting and providing relevant content to you on the mobile app and website
Understanding your needs to help us improve the mobile app and website
Improving search results
Understanding mobile app and website usage to help us improve our marketing or the way we do business
Sending you notifications, emails and other communications (more details below).
You give us permission to use your information for the above purposes in relation to our current service, and also in relation to any new products and features which we may provide to you in the future as part of our service.
The over-riding principles we apply are these:
We will not supply your information to any third party for any exploitation, commercial or otherwise.
We will not sell or otherwise provide the lists of our Users’ email addresses or any other personally identifiable information to any third parties;
The details you provide on Registration are only available to you, except that names and Users’ locations (city, county/state and country) and sustainability choices, if shared by the User, are searchable by other Users. Your email address is never revealed.
Emailing through Ailuna. We do not directly make your email address available to anyone on any screen Ailuna. The only legitimate way of making contact with another User on Ailuna is via the community functionality or via direct messaging which is available for Users who are connected as friends on Ailuna. Sent and received messages may appear in a User’s Ailuna inbox for an indefinite period – we do not delete it after any specific period. However, this does not mean that we will retain your messages forever; there may come a time when we will need to delete some or all of it, for technical or other reasons. In this event, we will endeavour to give you advance warning that we are going to do so.
Changes in Ailuna’s business. If all of the assets which Ailuna uses to operate its business (or substantially all of them) are acquired by a third party, we may transfer personal data we then hold to that party so that the acquirer can continue to provide Ailuna.
Place of storage and processing. The data that we collect from you is stored within the UK and broader European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the UK and EEA. Any such transfer of your Personal Data will be carried out in compliance with applicable laws.
4. Security. How do we protect your Personal Data?
We have taken technical and organisational measures to protect your data from loss, manipulation and unauthorised access. We continually adapt our security measures in line with technological progress and developments.
To make card purchases with us as secure as possible, all information is sent in encrypted form. This means that the information is passed through a secure connection and that external parties cannot read your Personal Data. For card purchases, we work with PCP compliant Payment Service Providers that help us to check directly with your bank that the card is valid for purchases.
Our Payment Service Providers process your card details according to the international security standards PCI DSS, which was developed by the card companies VISA, MasterCard, Diners, American Express and JCB. This means that your card details are processed with a very high level of security. When you pay by card, we reserve the right to carry out an identity check.
The mobile app and website is secured using an SSL Certificate so all web pages are served via https:// meaning the data us encrypted.
We encrypt your password within our database to maintain your security.
We also suggest Users protect themselves against unauthorised access to Your Details by following these rules:
no-one else uses Ailuna on that User’s machine while it is “logged on” to Ailuna;
to log off or exit from Ailuna when not using it; and
to keep his/her password secret.
5. Removing your profile from Ailuna and how long data is stored
You may remove your profile from the mobile app and website by using the “Cancel My Ailuna” option. Your account and any public content you have added to the mobile app and website will be REMOVED from ailuna.com and any other Ailuna instances; your profile page will not be accessible, and other subscribed Users will not be able to contact or find you.
When your profile has been removed, we will retain and use your Personal Data as necessary to be able to re-activate your account with us, if you wish to do so, comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain your Personal Data until 5 years after the end of the year in which you delete your Account in order to comply with our legal obligations pursuant to the Data Protection Act (DPA 2018) or for the establishment, exercise or defence of legal claims
6. Who is responsible for your Personal Data?
Chillisalsa Limited, Inca, The Lane, Lyford Wantage, Oxfordshire OX12 OEE, United Kingdom (Company Number 09440691) is the controller of the Personal Data you submit to us and responsible for your Personal Data under GDPR.
7. What are your rights?
You have the right to request information about the Personal Data we hold on you at any time. If your Personal Data is incorrect, incomplete or irrelevant, you can ask to have the information corrected or removed. You also have the right to request the processing of your Personal Data restricted and in some circumstances to data portability. We cannot remove your Personal Data when there is a legal storage requirement, such as accounting rules or when there are other legitimate grounds to keep the data, such as unsettled debts. You can withdraw your consent to us using the Personal Data for marketing purposes at any time.
8. Disclosure for legal reasons
We reserve the right to communicate any personal information we hold about you to third parties which seek the disclosure of it, and which make a legally-compliant request for its disclosure.
10. Contacting Ailuna
11. Links to third party sites
Ailuna contains links to other sites. Ailuna is not responsible for the privacy practices, or the content, of those web sites.
12. Data Protection Information and Complaints
You can obtain further information about data protection laws by visiting the UK Information Commissioner’s mobile app and website. You can search for our Data Protection Notification there, should you so wish (our registration number is: ZA746173).
You may file a complaint with the Information Commissioner’s Office if you are dissatisfied with our processing of your Personal Data. You can find the contact details of their website ico.org.uk.
13. Updating your personal information
If the information we hold about you is no longer correct, please update your details in My Ailuna or, alternatively, let us know and we will update our records. In certain situations, we may choose not to amend your personal information. In this event, we will include an appropriate statement or note about it with the information.