Privacy Policy

 

Introduction

Welcome to Little Wish List's - Privacy Policy.

Little Wish List Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you how we collect and handle your personal data when you visit our website (regardless of where you visit it from) or provide us with your personal details, and tell you about your privacy rights and how the law protects you. Please use the Glossary below to understand the meaning of some of the terms used.

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Little Wish List Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you create an account with us, sign up to our newsletter, purchase a product or service, take part in a competition or interact in any way with this website.

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

Little Wish List Limited is the controller and responsible for your personal data (collectively referred to as “Little Wish List”, "we", "us" or "our" in this Privacy Policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Little Wish List Limited

Email address: hello@littlewishlist.com

Postal address: 3rd Floor, 86-90 Paul Street, London, EC2A 4NE

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 do contact us in the first instance using the details above.

Changes to the Privacy Policy and your duty to inform us of changes to your Personal Data

We keep our Privacy Policy under regular review. This is the first version, uploaded on 3rd September 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, apps and social plugins

This website may include links to third-party websites, plug-ins and applications. Clicking on those links, adding links of your own to third party websites 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. Whenever you add a link to a third party website to your list or whenever you leave our website, we encourage you to read the Privacy Policy of every website you visit.

We may share your personal data with third party app or social media providers, if you have linked your account to their app or service and, by linking your account in such manner, you hereby consent to the sharing of personal data. We recommend that you read any terms and conditions and privacy policy for any third party app provider to which your account is linked for further information as to how your personal data will be stored and processed by them. We do not accept any liability for the use of personal information by such providers.

2. 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 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 includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing 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 donations made towards gift lists and products which you have purchased from or through us.

• Technical Data includes internet protocol (IP) address, 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 this website.

• Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.  

• Usage Data includes information about how you use our website and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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.

3. How is your personal data collected?

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

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• add an item to a list or make a payment towards a list;

• sign up to use our services;

• create an account on our website;

• subscribe to our services or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a)analytics providers;

(b)advertising networks; and

(c)search information providers.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

• Identity and Contact Data from data brokers or aggregators.

• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. 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, under whose terms we provide our services.

• 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.

Please see the “Lawful Basis” and “Glossary” sections below 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/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user of our services	(a) Identity (b) Contact	Performance of a contract with you, under whose terms we will provide our services
To manage our relationship with you which will include: (a) Sending you activity and account notifications (b) Notifying you about changes to our terms or Privacy Policy (c) 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 administer and protect our business and this website (including participation in affiliate programmes, 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, participation in affiliate programmes, 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) Technical (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 and allow associated third parties to make direct marketing communications 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.

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, used our service or purchased goods through us and you have not opted out of receiving that marketing.

Our Website makes use of both "open-tracking" and "click-tracking" in our HTML newsletters (i.e. emails that contain text and images). Open-tracking allows us to find out how many people have viewed our email newsletters and click-tracking allows us to find out which links in the newsletter were clicked on. This helps us to refine and improve the editorial content of our website’s newsletters, and to provide you with relevant information.

Third-party marketing

We will always obtain your express consent before we share your personal data with any third party for marketing purposes.  Provided you have given your consent, which is a requirement for receiving some of our products and services, we may from time to time send out emails on behalf of other businesses whose product and services may be of interest to you, or share your data with other carefully selected third parties which will allow those third parties to contact you directly about products and services that we think we may be of interest to you.

Our website allows other companies, called third-party ad servers or ad networks, to serve advertisements within our website. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on our website. They may also use other technologies (such as cookies) to measure the effectiveness of their advertisements and to personalise the advertising content you see.

Our website does not provide any personally identifiable information to these third-party ad servers or ad networks without your consent or except as part of a specific programme or feature for which you will have the ability to opt in or opt out. However, please note that if an advertiser asks our website to show an advertisement to a certain audience (for example, men aged 18-34) or audience segment (for example, men aged 18-24 who have viewed certain channels of content) and you respond to that advertisement, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. The advertiser may also use information regarding your use of our website, such as the number of times you viewed an ad (but not any personally identifiable information), to determine which ads to deliver to you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message which we send to you or by contacting us at any time using the details provided above.

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 purchase, service experience or other transactions.

Cookies

To enhance your experience of our website, all of our web pages use "cookies." Cookies are text files we place in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, once you choose to furnish the site with personally identifiable information, this information may be linked to the data stored in the cookie.

We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalise your experience of our website (e.g. to recognise you by name when you return to our website), save your password in password-protected areas, and enable you to use shopping carts. We also may use cookies to offer you products of potential interest in emails. If you do not wish to receive cookies, or want to be notified of when they are placed, your browser may permit you to do so. However, this will inhibit the functionality of our website on your browser.

We use the following cookies:

• Strictly necessary cookies, These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Protecting yourself

Our website has "Public Areas" where users can post personal content. When you disclose personal information in Public Areas, that information can be collected and used by others in various ways, including by sending unsolicited messages. You are solely responsible for any postings you make in Public Areas on our website, and for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you're online.

You can help to protect your information by safeguarding your Website password, using caution and discretion when posting information on Public Areas of our website. In addition, it is important that you keep us updated with your most current contact information. To review and make changes to your profile, please visit the settings page.

Any personal information or content that you voluntarily disclose online in our website’s Public Areas becomes publicly available and can be collected and used by others.

When you create an account on our website, some information regarding your account and your account activity will be provided to other users of our website. This may include the date you opened your account, the date you last logged in to your account, your age (if you choose to make it public) and your location.

You can also choose to add personal information that will be visible to other users on your profile page (the public facing page for your account on the site). This may include a profile picture, your name, gender or other details.

If you choose to add certain features to your profile page, these features and your activity associated with these features will be displayed to other users and may be aggregated and shared with your confirmed connections or other users. Such shared activity may include our website’s content you add as favourites.

When you add content to Public Areas of our website, this content can be viewed by other members. You shall grant to us the right to upload this content to Public Areas of our website and use it elsewhere on our website, our website’s social media channels, our website’s email newsletter communications and associated Little Wish List Limited products and services.

You can control the information that is available to other users of our Website and your confirmed friends and group members at any time, by editing your account and the features included on your profile page. You may update or correct your personal profile information and email preferences at any time by visiting your account profile page.

You must not disclose personally identifiable information relating to any third party on our Website unless you have their express consent to do so.

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.

5. 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 Purposes for which we will use your personal data” above.

• Third Parties as set out in the Glossary.

• 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.

6. International transfers

We need to share your personal data with third party suppliers of goods and services which you may purchase through us. This may involve transferring your data outside the European Economic Area (EEA).

Whenever 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:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are certified under the EU-US Data Privacy Framework, which replaced the former US Privacy Shield in 2023 and ensures that any personal data transferred outside the EEA to the US is provided an equivalent level of protection and security as required under GDPR.

between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. 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. Our Website has security measures in place to protect against the loss, misuse or alteration of the information under our control, and server is located in a locked, secure environment. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access to our services or making corrections.

We use the latest security technology to protect your personal information. When you enter your personal details in any of our pages, you are in a secure website. Most browsers display a small padlock symbol on your browser to reassure you this is secure. It is your responsibility and not that of our Website to ensure your browser is up-to-date and has the relevant security patches. Most web browsers will display a message too stating that you are entering into a secure website. If at any time you leave the secure area of our Website, your web browser may remind you that you are leaving a secure part of our website. You will be asked if you want to cancel this reminder for future occasions.

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.

Unfortunately, the transmission of information via the internet is not 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; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. 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.

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, regulatory, tax, accounting or other 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 and regulatory 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.

9. Your legal rights

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

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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.

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 the 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:

• If you want us to establish the data's accuracy.

• 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.

• 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 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 legal rights, please contact us using the details set out above.

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest 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

Third Parties

• Service providers acting as processors based inside and outside the EEA who provide IT and system administration services.

• Third party retailers supplying products within the content of any list created by our users

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom 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.