Privacy Policy
INTRODUCTION
Gift of Kit is committed to protecting your personal information and your right to privacy.
If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at privacy@starlingbank.com.
When you visit our website www.kickonwithstarlingbank.com (“Website“), to apply to be a part of the Kick On with Starling programme (“Programme”), we appreciate that you are trusting us with your personal information. Gift of Kit (“We“) takes your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of the Website and Programme immediately.
This privacy notice applies to all information collected through the Programme and Website, and for its purposes, Kit for Sport Limited, doing business as Gift for Kit, is a data processor on behalf of Starling Bank Limited.
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you provide to us when you register on the Website for the Programme, or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make. The personal information we collect may include the following:
Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; usernames; passwords; contact preferences; and other similar information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for the purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We may process or share your data that we hold based on the following legal basis:
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Lawful basis for processing |
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To administer the Programme and manage your account. We may use your information to administer the Programme including your application for the Programme and manage your account in connection with it. |
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Fulfill and manage your orders. We may use your information to fulfill and manage any orders, payments, returns, and exchanges you make through the Website in connection with the Programme. |
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For feedback and case studies. We may share your application details for the Programme with Starling Bank so that they may contact you regarding your involvement with the Programme to obtain your feedback and case studies . If you do not wish for Starling Bank to contact you, please contact us at privacy@starlingbank.com and be sure to include your name and contact information. Starling Bank will not post any case studies without your consent. |
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To update you on any future Programmes. We may contact you to advise you of any Programmes that Starling Bank may run in the future. |
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To send administrative information to you. We may use your personal information to send you information about changes to our terms and conditions, and policies. We will process your data for our legitimate interests. |
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To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention). |
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To enforce our terms and conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contracts. |
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To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. |
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To respond to user enquiries/offer support to users. We may use your information to respond to your enquiries and solve any potential issues you might have with the Programme. |
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WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We may share your personal data with the parties set out below for the purposes set out in the table \
HOW DO WE USE YOUR INFORMATION? above.
- Starling Bank Limited
- Third party service providers of Gift of Kit, to facilitate and support your participation. Not limited to: Kitlocker.com, Intuit Mailchimp.
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in the cookie notice at www.kickonwithstarlingbank.com
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice, or for 12 months, which is longer, unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, or for 12 months, whichever is longer. We may be required to keep your personal information for longer if required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
You have the right to withdraw the consent you have given above at any time by contacting us at privacy@giftofkit.com. This will not change our basis for dealing with the personal data before consent was withdrawn. If consent is withdrawn we may remove and delete any personal data of you in our control.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Contact us at privacy@starlingbank.com
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, to complete our contractual obligations and/or comply with applicable legal requirements.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us at privacy@starlingbank.com. We may still be required to communicate with you for service-related or for other non-marketing purposes.
DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at dpo@starlingbank.com
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email privacy@starlingbank.com.