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Privacy Policy

Last updated: 13th February 2018

This Policy explains when and why we collect Personal Data about the people who visit our website or other platforms such as, mobile applications, email, text messages, chatbots and social media accounts (“Platforms”), how we use such data, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally to ensure that you are happy with any changes. We will notify you of any material changes on how we use your Personal Data prior to implementing them. Notification of any such material change will be made by email or prominent notice on our website. By using our Platforms, you’re agreeing to be bound by this Policy.

Who are we?

We are Icelolly Marketing Limited (icelolly.com, or we or us), a company incorporated and registered in England and Wales (company number 05655962), whose registered office is at 19 – 20 Park Row House, Park Row, Leeds LS1 5JF. We are committed to protecting and respecting your privacy.

If you would like any more information or you have any comments about our Policy, please either write to us at Data Protection Manager, Icelolly Marketing Limited, 19-20 Park Row House, Park Row, Leeds LS1 5JF, or email us at data.protection@icelolly.com.

Your choices and right to withdraw consent

When you first give us Personal Data through our Platforms, we will ask for your consent to contact you about our services, and those of our partners who provide services featured or included on our Websites or Platforms (“Partners”).

We are currently working on the preference centre that will be available on our website. This will enable you to make certain choices about how we can contact you. You will need to register with our website before you make such choices.

We will not process your Personal Data without your consent and, unless we tell you otherwise, consent will be the basis on which we process your Personal Data.

You can withdraw consent at any time for us to process your Personal Data and to direct market to you by; (i) clicking UNSUBSCRIBE or other opt-out urls on any marketing email you receive from us (ii) clicking the unsubscribe link. https://www.icelolly.com/emailoffers/unsubscribe

Your Rights

Subject Access Requests

You are entitled at any time to obtain information about all your Personal Data that we hold about you, in accordance with the Act. We may request proof of your identity before providing this information and may not be able to allow you to access certain Personal Data in some cases. For example, if your Personal Data is connected with Personal Data of other persons, or for legal reasons. In such cases we will provide you with an explanation why you cannot obtain this information. Please note there may be a small administration fee for the provision of the information requested.

If you would like access to the Personal Data that we hold about you, you can do this by emailing us at data.protection@icelolly.com (or writing to us at the address stated above under the heading Who Are We?)

Updating your Personal Data

We control the processing of Personal Data on our Platforms with the aim of keeping the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you we will, subject to any statutory provisions, (especially those affecting our accounting, processing of claims and mandatory data retention which may prohibit deletion or anonymization), delete it or correct it promptly.

Please email us at data.protection@icelolly.com or write to us at the address above to update your Personal Data.

Your new rights under GDPR

Your rights will be enhanced when the European General Data Protection Regulation (GDPR) comes into force. GDPR is due to come into force on 25th May 2018.

When GDPR comes into force you will have the following rights:

  • to prevent automated decision-making and profiling;
  • a right to be forgotten and to have Personal Data erased;
  • a right to complain to the regulatory authority (Information Commissioners Office).

Further information on these rights and GDPR can be found at https://ico.org.uk.

We will update this Policy when GDPR comes into force to reflect the above new rights.

The types of Personal Data we collect

When you use or visit our Platforms, we may collect information from you. Some of it may be Personal Data. This information can include search history, IP address, screen resolution, browser used, operating system and settings, access times and referring URL. If you are using a mobile device, we may also collect data that identifies your device, your settings and your location.

If you choose to register or login to our Platforms using your email address, we may collect your email address and password. If you choose a third-party service, like Facebook login, to register or login to our Platforms, you are permitting us to use and store the profile information related to your social media account.

When you give us Personal Data, you are telling us that the information is true, accurate, complete and current. You are also telling us that you have the authorisation to provide it to us.

How we collect your Personal Data

We collect your Personal Data:

  • Directly from you - For example, when you provide us with your Personal Data when you register with our Platforms or use our online chat products.
  • Passively - For example, we collect information about you over time when you visit our Platforms. We also use tracking tools like cookies, analytical tools and beacons.
  • From third parties - This can include when you log in using a third-party platform, such as Facebook.

Platform features may make use of your device attributes and settings that will allow us to determine your physical location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies.

Why we collect your Personal Data

We may use your Personal Data to enhance and personalise your experience and provide you with offers and services that may be of interest to you. For example, we may help you find deals flying from your closest airport or send you messages that may be of interest to you based on your current location.

icelolly.com does not have control over your device settings, but we recommend enabling location services on your device so that you can take advantage of the location based features and functionality offered.

Using your Personal Data

Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:

  • To provide you with the products you are looking for, and improve our Platforms and services.
  • To better understand the users of our Platforms and services, to protect our property and to prevent damage to them.
  • To display more relevant advertising and recommendations or suppress advertising and content that you might find irrelevant.
  • To contact you as follows:
    • To send alerts and notifications you have subscribed to, including to your mobile device;
    • To solicit reviews;
    • To send you marketing emails from an icelolly.com address regarding our services or those of our partners, if you have opted-in to receive emails from us;
  • To estimate our audience size and usage pattern;
  • To store information about your preferences, and so allow us to customise our Platforms according to your individual interests;
  • To speed up your searches;
  • To recognise you when you return to our Platforms.

How we share your Personal Data

We will not share your Personal Data with third parties except with your consent. We may need to share your Personal Data with our Partners, for example, any feedback on their services, in which case we will obtain your consent before we do so.

We may share your Personal Data as otherwise described to you at the time of collection. For example, if you provide information to enter a competition, we may share your Personal Data with promotional or business partners for the purposes of entering such competition.

In in the event of a sale of our business, or a reorganisation of our business , or as otherwise required by law or applicable regulator, we may transfer Personal Data to third parties (as part of the information generally contained in business) but such transferred data would be subject to this Policy and will not be transferred unless the recipient can commit to keep your Personal Data secure and in accordance with applicable privacy laws.

If you provide a review of your trip via our website or on a linked website, you authorise us to publish it on all our Platforms under the screen name you provided on our website or the linked website. You also authorise us to aggregate it with other reviews.

We may disclose Personal Data if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your Personal Data if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.

We may disclose your Personal Data to any member of our group of companies, which means any subsidiary or holding company of icelolly.com and a "subsidiary" includes a "subsidiary" and a "subsidiary undertaking" (each as defined in the Companies Act 2006) and a "holding company" includes a "holding company" and a "parent undertaking" (each as defined in the Companies Act 2006).

We do not knowingly collect Personal Data from minors (persons under the age of 18 years). If we become aware that a minor is attempting to submit Personal Data, we will remove this Personal Data from our records. If you are the parent/legal guardian of a minor who has given us Personal Data, please contact us immediately at Data.Protection@icelolly.com so we can delete it.

We may also share anonymous aggregated usage information with others.

How we store and protect your Personal Data

Our servers and data centres are located in the European Union (EU). However, we may need to transfer your Personal Data to staff operating outside the EU who work for us or for one of our Partners. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. By submitting your Personal Data, you agree to the transfer of Personal Data to countries outside the EEA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. Subject to the applicable laws in such other non-EU countries, we will provide the necessary safeguards to maintain adequate protection of your Personal Data, for example, by obtaining from the data recipients contractual commitments based on the EU model clauses or by ensuring that such country has equivalent and adequate laws.

We have a security program intended to keep the Personal Data stored in our systems protected from unauthorised access and misuse. Personal Data may only be accessed by persons within our organisation or Partners to carry out the uses indicated in this Policy.

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 website and other Platforms; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.

Internet

Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

How long we keep your Personal Data

We will only keep your Personal Data for the purposes outlined in this Policy and when these purposes have expired, or are no longer relevant, or you have withdrawn your consent for us to use your Personal Data (and we have no other lawful basis to use such data), we will delete such data. In the meantime, we will continue to use your Personal Data to contact you in the manner set out in this Policy or otherwise for the purposes set out in this Policy.

Cookies, tracking tools and profiling

Cookies

When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer’s hard drive that records how you’ve used a website. These are called ‘cookies’. These cookies cannot be used to identify you personally and are used to improve services for you. So, for example, the next time you visit that website, it can tailor your options based on the information it has stored about your last visit.

To learn more about cookies, see www.allaboutcookies.org or www.google.com/policies/technologies/cookies/

Your browser may give you the ability to control cookies. How to do this varies from browser to browser. You should view the Help menu on the browser you use for further information. By turning off cookies, you might not be able to use some of the products or services on our Platforms.

We or our third-party service providers may set and use analytics cookies. These allow us to gather aggregated or segmented information about the types of visitors that access our Platforms and the pages and advertisements that they view.

We also use data collection cookies to enhance your use of our website. These cookies are used to help us understand how you engage with the icelolly.com website so we can tailor content based on your interests.

By using the icelolly.com website, you agree that we can place these types of cookies on your access device.

You may not be able to use any of the above features if you set your device to block cookies, delete cookies or opt out of online behavioural advertising.

Please note that our advertisers or suppliers accessed through links displayed on our website may also use cookies, over which we have no control.

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively.

Tracking tools

We, our advertisers and our business partners, use several common tracking tools on the Platforms and those platforms of our advertisers and partners. We use these tools in order to:

  • Track new visitors to our Platforms;
  • Help us recognise your browser as a previous visitor. This includes saving and remembering any preferences that may have been set while your browser was visiting our Platforms, such as language;
  • Store your username and password if you are registered with us;
  • Work with online advertising companies to display targeted advertising on our Platforms and third-party platforms that you visit. This targeting may be based on information you submit on our Platforms or third-party platforms. This targeting may also be based on your activities or behaviours on our Platforms or those of third parties;
  • Help improve our website offering and for capacity planning purposes. In particular, We, our advertisers and our business partners may use tracking tools such as web beacons. Web beacons are placed in the code of a web page or an email newsletter for the purpose of determining who has seen and engaged with the promotion or announcement and therefore its value to the customer and whether re-engagement is appropriate;

We may also use Google Analytics to collect demographic and interest data about you (such as age, gender, and interests), which enables us to improve our platforms and deliver content pertinent to the visitor. You can opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout.

By using our Platforms, you agree to our use of the profiling and tracking tools mentioned above.

Third-party websites

Our website and Platforms may contain links to other websites run by other organisations. This Policy applies only to our website and Platforms‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites and platforms even if you access them using links from our Platforms.

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.