Privacy and Cookies Policy

ScoresMatter- PocketShield Card- Privacy and Cookies Policy

BACKGROUND:

ScoresMatter Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, https://pocketshield.scoresmatter.co.uk/?_ab=0&_fd=0 (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

Definitions and Interpretation
1. In this Policy the following terms shall have the following meanings:
  1. “Account” means an account required to access and/or use certain areas and features of Our Site;
  2. “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
  3. “Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions in the Data Protection Act 2018 and the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019 and the UK-GDPR collectively referred to in this document as the “Data Protection Regulations”;
  4. “We/Us/Our” means ScoresMatter Limited, a limited company registered in England under company number 07686022, whose registered address is, of Building 1, Chalfont Park, Gerrards Cross, Buckinghamshire, SL9 0BG; and
  5. “UK” means the United Kingdom
Information About Us
1. Our Site is owned and operated by Us.
2. ScoresMatter and PocketShield are trading names of ScoresMatter Limited.
3. Our Data Protection Officer can be contacted by email at manager@scoresmatter.co.uk, or by post. Please address postal correspondence to: The Data Protection Officer, ScoresMatter Limited, Building 1, Chalfont Park, Gerrards Cross, Bucks, SL9 0BG.
What Does This Policy Cover?
This Privacy Policy applies only to your use of this Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
Your Rights
1. As a data subject, you have the following rights under the Data Protection Regulations, which this Policy and Our use of personal data have been designed to uphold:
  1. The right to be informed about Our collection and use of personal data;
  2. The right of access to the personal data We hold about you (see section 12);
  3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
  4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
  5. The right to restrict (i.e. prevent) the processing of your personal data;
  6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  7. The right to object to Us using your personal data for particular purposes; and
  8. Rights with respect to automated decision making and profiling.
2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
1. Depending upon your use of Our Site and/or our services, We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies):
  1. Name;
  2. home address and residential status;
  3. date of birth;
  4. Gender;
  5. contact information such as email addresses and telephone numbers;
  6. financial information such as credit / debit card numbers, bank name and account details;
  7. IP address;
  8. cookies and tracker information from your browser and/or device;
  9. web browser type and version;
  10. operating system;
  11. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
  12. where you contact us by phone, email or post a record of that contact; and
  13. where you contact us by phone we will retain a recording of that call;
How Do We Use Your Data?
1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Regulations at all times. For more details on security see section 7, below.
2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests (see 6.8 below for more details on this). Specifically, We may use your data for the following purposes:
  1. Fulfilling your order(s) that you place through Our Site;
  2. Personalising and tailoring your experience on Our Site;
  3. Personalising and tailoring Our services for you;
  4. Replying to emails from you;
  5. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us on contact@scoresmatter.co.uk, sending us a message via the contact from on the website;
  6. Market research (including reviews and surveys);
  7. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
  8. to manage your marketing preferences;
  9. to manage your data processing preferences;
  10. to compile anonymised data for analytical purposes.
3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and post with information, news and offers on Our products and/or services or those that you have shown an interest in. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Regulations (as may be amended from time to time).
4. We may contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services ('the Purpose'). We may use an external company, such as Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and reference number with Trustpilot for the Purpose. If you want to read more about how Trustpilot process your data, you can find their Privacy Policy here. We may also use such reviews in other promotional material and media for our advertising and promotional purposes.
5. Offers that we (or the third parties listed in 8.7.5 below) may send or refer you to will include information about our other products and services, offers from service providers that maybe the same or similar to what we provide, credit cards and loans (personal and short term), gaming, mobile phones, insurance, job boards and promotional offers such as free gifts, coupons and vouchers from retailers.
6. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
  1. As a general rule, unless we have been requested to delete Your information, Customer personal data will be kept for a period of up to six years after the order has been fulfilled. This is based upon the Limitation Act 1980 for the period in which someone can bring a breach of contract claim;
  2. Call recordings are retained for a period of 2 years from the date that the call is made to our customer services team.
8. Legitimate Interest
  1. Where we use legitimate interest for the basis of our processing of your personal data we shall ensure that we can demonstrate compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual.
  2. You have the right to object to our use of your personal data where we use legitimate interest as the basis of processing. You can do this by contacting us on the details in section 14.
  3. Our legitimate interests include:
    1. intra-group transfers;
    2. the maintenance of our IT/Data Security systems and processes;
    3. putting in place fraud prevention mechanisms;
    4. keeping our records up to date;
    5. working out which of our products and services may interest you and telling you about them (i.e. direct marketing);
    6. developing products and services;
    7. being efficient about how we fulfil our legal duties;
    8. maintaining a marketing suppression list; and
    9. complying with laws/regulations that apply to us.
How and Where Do We Store Your Data?
1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
2. All our customer data is sorted and accessed from our servers which are based in Ireland.
3. However, some or all of your data may be stored/transferred outside of the UK. You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and in compliance with the Data Protection Regulations including:
  1. Carrying out due diligence on prospective parties to which we wish to transfer the data to;
  2. Carrying out a risk assessment on the country to which we will transfer data to ensure that the protection offered to data subjects is equivalent to those provided in the UK, or accepted by the UK regulator as having adequate levels of protections (i.e. an adequacy decision exists)
  3. Having in place written contracts on the transfer and use of the data (or using model contract clauses or the ICO’s International Data Transfer Agreement) that sets out clearly the responsibilities of each party and the rights of data subjects;
  4. Transferring data in an encrypted form or using a secure file transfer protocol; and /or
  5. Limiting the transfer of data to only data that needs to be transferred to achieve the purpose.
4. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. Steps We take to secure and protect your data include:
  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.
Do We Share Your Data?
1. We may share your data with other companies in Our group for reporting purposes and servicing your account. This includes Our holding company and its subsidiaries.
2. We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, search engine facilities, advertising, and marketing companies. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
3. In order to provide you with our services (and comply with our contractual obligations) we may need to share some or all of your personal data with our service providers:
  1. Allsec Technologies Limited- customers support services;
  2. Bryton Interactive LLC- technology support services
  3. Amazon Web Services – hosting and server provider
  4. Mailmaster (Scotland) Ltd – postal mailing services
  5. SendGrid – emailing platform for sending email communications
  6. Mandrill ® - emailing platform for sending email communications
  7. TrustPilot A/S- customer feedback and reviews platform
  8. Shopify - Sales order management and fulfillment services provider and hosts our site.
4. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
5. We may sometimes use third party data processors that are located outside of the UK. Where We transfer any personal data outside the UK, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Regulations including:
  1. Carrying out due diligence on prospective parties to which we wish to transfer the data to;
  2. Having in place written contracts on the transfer and use of the data (or using model contract clauses/using the ICO’s International Data Transfer Agreement) that set out clearly the responsibilities of each party and the rights of data subjects; and/or
  3. Transferring data in an encrypted form or using a secure file transfer protocol;
  4. Limiting the scope of the data transfer to a ‘need to know basis’ only.
6. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
7. We may with your consent, or where it in our legitimate interest, also share some or all of your personal information with the following organisations:
  1. Our sister company in the UK– Your Social Insights Limited
  2. Our Parent Company- ScoresMatter, Inc, which is based in Atlanta, Georgia, USA
  3. Our affiliated company- IMT Marketplace, LLC, which is based in Atlanta, Georgia, USA
  4. Our technology service provider- Bryton Interactive LLC, which is based in Atlanta, Georgia, USA
  5. Our third-party marketing partners (for marketing, and/or auditing, reporting and analytics connected to marketing) which include:
    1. TFLI Limited
    2. T Dot UK Limited
    3. Nouveau Finance Limited
    4. D-L-U-K Limited
    5. Stop and Go Network Limited
    6. Facebook Ireland Limited (see 8.8 below for further details)
    7. STS Commercial Limited
  6. We may share your data with regulators and disputes resolution bodies such as:
    1. The Information Commissioner Office;
    2. Advertising Standards Authority;
    3. Local Trading Standards;
  7. A third party acting on your behalf, such as a financial or legal adviser;
  8. Our payment processor when we are dealing with payment disputes
  9. Our chargeback management providers Ethoca Inc and Verifi Inc when they notify us of a possible transaction dispute
  10. With our third-party marketing partners when we are dealing with a complaint (see the list above)
  11. Our service providers as listed in 8.3 and 8.5
8. We use the services of Facebook Ireland Limited (Facebook) to carry out certain marketing activities on the Facebook Platform. Specifically, from time to time we use Facebook’s Audience Insights to help us to create targeted audiences for our advertising campaigns on Facebook. This involves sharing some of our customer personal data with Facebook to allow it to create for us information on the types of audiences (i.e. potential customers) on Facebook platform that would be best suited to see our adverts. In this respect Facebook acts as our joint processor.
  For such processing of your personal data we and Facebook also act as a ‘Joint Controller’ this means that both Facebook and us can determine the reasons for processing of your personal data. Facebook has its own privacy policy on how Facebook processes personal data, including the legal basis which Facebook relies on and the ways to exercise Data Subject rights against Facebook. To review Facebook’s privacy policy, you can visit: https://www.facebook.com/about/privacy. You can also obtain full contact details of Facebook or its representative and the details of its Data Protection Officer from this policy.
  
  In order to ensure the rights of data subjects (i.e. you) we have entered into a Controller Addendum with Facebook that sets out each parties’ respective responsibilities in terms of this processing and our responsibility to inform you of the details in this section 8.8.
  
  Any data subject requests with regard to the Personal Data stored by Facebook Ireland after the Joint Processing described in paragraph one of this section 8.8, is the responsibility of Facebook.
What Happens If Our Business Changes Hands?
1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
How Can You Control Your Data?
1. In addition to your rights under the Data Protection Regulations, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you control on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Your Right to Withhold Information
1. You may access Our Site without providing any data at all.
2. You may restrict Our use of Cookies. We will give you the opportunity when you first visit our side to accept or reject cookies. For more information, see section 13 a.
How Can You Access Your Data?
1. You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the Data Protection Regulations, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at contact@scoresmatter.co.uk, or using the contact details below in section 14.
Our Use of Cookies
In this section:

“Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined in the Data Protection Act 2018 and the EU Regulation 2016/679- which is incorporated into UK law under the Data Protection and Privacy Electronic Communications (EU Exit) Regulations 2019 (referred to collectively here as the “Data Protection Regulations”).

“Shopify” means Shopify International Limited which hosts our Site, (www.shopify.com).
1. Our Site is hosted by Shopify and when you visit Our Site it may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us (or in this case Shopify) and are used only by Us/Shopify. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services.
2. By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us/Shopify. Third party Cookies are used on Our Site for analytical purposes.
3. Some or all of the following types of Cookie may be used:
  Strictly Necessary Cookies- A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
  
  Analytics Cookies - It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
  
  Functionality Cookies - Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
  
  Targeting Cookies- It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. Some information gathered by targeting Cookies may also be shared with third parties.
  
  Third Party Cookies- Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us
  
  Persistent Cookies - Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
  
  Session Cookies - Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
4. Before Cookies are placed on your computer or device, you will be shown a pop-up message requesting your consent. By giving your consent to the placing of Cookies you are enabling Us/Shopify to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies unless those Cookies are strictly necessary; however certain features of Our Site may not function fully or as intended. To see the details of the cookies that are placed on your device please see: https://www.shopify.com/legal/cookies which details the different types of cookies and the duration of these cookies.
5. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
6. The links below provide instructions on how to control Cookies in all mainstream browsers:
  1. Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
  2. Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
  3. Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
  4. Safari (macOS): https://support.apple.com/en-gb/guide/safari/sfri11471/mac
  5. Safari (iOS): https://support.apple.com/en-gb/HT201265
  6. Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
  7. Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
Contacting Us
If you have any questions about Our Site or this Policy, please contact Us by email at contact@scoresmatter.co.uk, or by post at ScoresMatter, Building 1, Chalfont Park, Gerrards Cross, Buckinghamshire, SL9 0BG. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).
Changes to Our Privacy and Cookies Policy
We may change this Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of this Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.