Privacy Policy
January 2022
Version 4
Furthr Privacy Policy
This Privacy Policy describes how your personal information is collected, used, and shared as a customer of Furthr Ltd including the use of the website www.furthr.earth (the “Site”).
Data Controller & Processor
The data controller & processor is Furthr Ltd and is responsible for your personal data, also referred to as “we”,”us” or “our” in this privacy policy.
WHAT PERSONAL INFORMATION WE COLLECT, HOW AND WHY WE USE IT
Any information about an individual from which a person can be identified is considered personal data (also known as personal information). Data where the identity has been removed (anonymised) is not considered personal data. Note that sentences at the end of "How & Why" paragraphs, following a dash ("-"), refer to why we use your personal information, also considered the lawful basis for processing.
Device Information
What
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “device information”.
We collect device information using the following technologies:
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” “cookies” and “pixels” are electronic files used to record information about how you browse the Site.
How & Why
We use the device information that we collect to help us screen for potential risk and fraud (in particular, your time zone and IP address). All customers of Furthr should be residents of one of the Eligible Prize Draw Countries to be eligible to enter into our prize draws and this is one way we check this. - needed to comply with legal obligations.
We also use device information (and sometimes contact information from your order information) to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site), for advertising campaigns and to assess the success of our marketing and advertising campaigns). - for our legitimate business interests (improving the site, the service and our advertising to you).
Order Information When You Make a Purchase
What
When you make a purchase through the Site, we collect certain information from you, including your name, payment information (including credit card numbers), billing address and email address. We also collect transaction details and financial information about your Furthr purchases, to manage your Furthr account and enter you into our prize draw if you are on a prize draw plan and a resident in one of the Eligible Prize Draw Countries. If you enter our prize draws through postal entry we will also collect your name, email address and consent to be contacted if you win. We refer to all of this information as “order information.”
Please note that payment information is never stored on Furthr servers and is only stored with our PCI compliant payment processor.
How & Why
We use your order information to register you as a new customer, enter you into a subscription and enter you into any prize draws where applicable. - to carry out the contract in place with you.
We will use your order information with our service providers and suppliers to complete certain functions on our behalf, including email software, survey software, secure data transfer, customer relationship management, technical, logistical or other functions, as may be required, so we can fulfil your orders - to carry out the contract in place with you.
We will also use your name and email address to contact you in the event that you win a prize for us to facilitate our online payment processor to send you your prize or to confirm the address you would like a prize to be sent to. - to carry out the contract in place with you.
We use transaction details and financial information to enter you into prize draw if applicable and keep your personalised impact metrics up to date. - to carry out the contract in place with you.
We use your name, email address and in some cases transaction details and financial information to respond to requests from you in order to manage our relationship with you. - to carry out the contract in place with you, - needed to comply with legal obligation, - for our legitimate business interests (to keep our data we hold up to date).
We may use your name and email address to take part in market research (including but not limited to a survey or request for an interview). - for our legitimate business interests (improving the site, the service and our advertising to you).
Order Information When You Sign Up Via A Benefits Provider Or Platform
What
When you sign up to our services via a benefits provider or platform, we collect certain information from you, including your name, company and email address.
How & Why
We use your order information to register you as a new customer, enter you into a subscription and enter you into any prize draws where applicable. - to carry out the contract in place with you.
We will use your order information with our service providers and suppliers to complete certain functions on our behalf, including email software, survey software, secure data transfer, customer relationship management, technical, logistical or other functions, as may be required, so we can fulfil your orders - to carry out the contract in place with you.
We will also use your name and email address to contact you in the event that you win a prize for us to facilitate our online payment processor to send you your prize or to confirm the address you would like a prize to be sent to. - to carry out the contract in place with you.
We use your name and email address to respond to requests from you in order to manage our relationship with you. - to carry out the contract in place with you, - needed to comply with legal obligation, - for our legitimate business interests (to keep our data we hold up to date).
We may use your name and email address to take part in market research (including but not limited to a survey or request for an interview). - for our legitimate business interests (improving the site, the service and our advertising to you).
Prize Winners
What
As our prize winners must be residents of one of the Eligible Prize Draw Countries and over the age of 18 or the age of majority, we require proof of address (utility bill or bank statement) before we can send both cash prizes and third party products. We will also require proof of age (Drivers licence) for those who win third party products. If the prize winner has won cash we require the email address linked to the prize winner’s PayPal account to pay the monies to but also evidences the winner is over the age of 18 (PayPal accounts only available for over 18s).
How & Why
We will look at your name, address, email address and age in order to prove your identity as being a resident of one of the Eligible Prize Draw Countries and over the age of 18 or the age of majority - needed to comply with legal obligation.
Marketing
What
Our site has sign up forms for users who want to be included in ongoing newsletters about Furthr’s progress and upcoming events. This signing up for newsletter and marketing materials will collect your name, email address and your consent to be contacted with marketing materials.
If you want to opt out of any marketing materials being sent to you, you can do so by following the link in the marketing materials previously sent to you or emailing us directly using the contact information at the bottom of the page.
How & Why
We will use your email address, consent and name to provide you with newsletters and other marketing materials. - consent.
We may use information about your use of the site, combined with technical information about your device and (in some situations) your contact and personal information, along with other relevant information that we collect from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant content to the site and other direct marketing to you through various channels, including on social media platforms. - consent, - for our legitimate business interests (improving the site, the service and our advertising to you).
Correspondence Information
What
We may collect your name, email address and any other personal data you disclose through correspondence with Furthr. This may be through complaints, questions and queries about Furthr as part of email exchange or live chat. We may also collect personal data such as your email address, name and social media username if you interact with us through social media channels.
How & Why
We will use your email address and name in order to respond to any questions, complaints or queries you may have. - needed to comply with legal obligation, - for our legitimate business interests (in responding to any complaints, questions or queries ).
We may also use information about any transaction, financial information, copies of your correspondence with us, information about your use of the website, or technical information in order to deal with any complaint, request or query from you. - needed to comply with legal obligation, - for our legitimate business interests (in responding to any complaints, questions or queries ).
Childbase Partnership Sustainable Travel Challenge
What
As part of the Childbase Partnership Sustainable Travel Challenge we collect users first name and email address. We may also inadvertently collect other personal data disclosed through correspondence with Furthr or survey responses. This may be through survey feedback, survey answers, complaints or questions about Furthr as part of email exchange, surveys or live chat.
How & Why
We collect first name and email address as part of an initial optional survey for users, which, once captured, enables us to provide our services to users. Users can withdraw this consent at any time. We use this personal data exclusively for providing services relating to carbon footprint measurement and reduction advice. We also collect consent when capturing this information that users are happy with our use of their personal data in order to be provided our services. This personal data is shared with our digital survey software provider and email service provider. This personal data may be transferred outside of Europe, including to Canada and the United States, in accordance with the purposes outlined in this paragraph. - consent; - to carry out the contract in place with you.
SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
We share your personal information with trusted third parties to help us provide you the service, we do this in accordance with the applicable law and for the purposes outlined above.
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Payment providers - this includes signing up to a subscription plan to create a monthly payment as well as us being able to send you prize money should you win.
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Our IT systems providers - in order to capture your order information and set you up as a customer, manage your account and communicate with you. This includes support, hosting and software licensing.
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Marketing service providers - enables us to send emails and communications to you.
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Digital survey companies - in order for us to conduct market and user research through surveys.
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Social media platforms - in order to provide advertisements as well as for the purposes of undertaking profiling and behavioural modelling.
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Online analytics companies - for us to run analytics on our website and understand how customers are using our service including the effectiveness of marketing.
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Other third party providers - to any other third party where you have provided your consent directly with them.
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Finally, we may also share your personal Information to comply with applicable laws and regulations where a lawful request for information has been received.
We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your personal Information here: https://www.google.com/intl/en/policies/privacy/. (You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout .)
INTERNATIONAL TRANSFERS
Please note that your personal information may be transferred to third party providers who may process data outside of Europe, including to Canada and the United States, in accordance with the purposes outlined in this privacy policy. Customers are entitled to know about the legal basis of Data transfers to a country outside the European Economic Union and about the security measures taken by Furthr and third parties to safeguard their personal information.
Customers can find out more about what safeguards and measures for the protection of privacy rights Furthr has put in place by contacting Furthr using the information provided in the contact section.
DATA RETENTION
Personal information will be retained for as long as is required by the purpose it is being collected for. Unless longer retention is required to comply with regulatory mandates or where we have a legitimate and lawful reason.
Where personal information has been collected in order to carry out the contract in place with customers, Furthr will retain the data for as long as the contract is still being completed.
Where personal information has been collected for legitimate business interests, data will be retained for as long as is necessary to complete those business interests, which are outlined in this privacy policy.
Where a customer has given consent for the collection and processing of personal information, Furthr may continue to process data up until the customer withdraws consent.
Once a retention period ends personal information will be deleted. After deletion, the right to rectification, the right to erasure, the right to access and the right to data portability cannot be fulfilled.
Data Protection and Privacy Commitments
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As part of our commitment to data protection and privacy at [Your Company Name], our privacy policy incorporates crucial elements typically found in a Data Processing Agreement. This approach ensures that we maintain compliance with relevant data protection laws and regulations, such as the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, without the need for a separate DPA.
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Key Elements Included in Our Privacy Policy:
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Incident Reporting: In the event of a security incident or data breach, we commit to notifying the relevant parties promptly, aiming for within 48 hours, to facilitate immediate and effective action.
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Data Subject Rights: We provide assistance with requests pertaining to data subject rights, ensuring compliance with individuals’ rights under data protection regulations.
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Legal and Regulatory Compliance: Our policy and practices are aligned with national and international data protection laws, with regular updates to ensure ongoing compliance with evolving standards.
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Data Processing Standards: When processing data on behalf of clients or third parties, we adhere to strict security and confidentiality standards, consistent with our role as a data processor.
YOUR RIGHTS
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You have the right to request / access personal information we hold about you (also known as a subject access request)
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You can ask that your personal information be corrected, updated, or deleted
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You can request the restriction of processing your personal information. This would suspend the processing of your personal information under the following scenarios:
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If you have disputed the accuracy of our data about you and we are verifying that claim.
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You can contact our Data Protectio officer at srujan@furthr.earth
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Where the processing of your personal information has been unlawful but you do not want us to delete it
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Where we no longer need your personal information but you need us to still hold your personal information as you need it to establish, exercise or defend legal claims
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You have objected to the processing of your personal information and we are in the process of verifying if we have legitimate grounds override those of the individual.
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You can request your personal information be transferred to another data controller. This means we will provide to you, or a third party of your choice, your personal information in a structured, commonly used, machine-readable format. This only applies to automated information you initially provided to us with consent and was then used for the carrying out of the contract with you.
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You have the right to object to the processing of your personal information where we claim processing under legitimate business interests, if given your specific circumstances you feel it is impacting your fundamental rights and freedoms. You also have the right to object to the processing of your personal information for direct marketing purposes.
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You can withdraw consent at any time where you have previously given consent to the processing of your personal information.
Finally, you also have the right to make a complaint with the relevant data protection authority if you think that your personal information is not being processed in accordance with applicable data protection law.
If you would like to exercise any of your rights, please contact us through the contact information below.
MINORS
The Site is not intended for individuals under the age of 18.
LINKS TO THIRD PARTY SITES
As part of our site we may have links to third party sites, please note that once on these third party sites you will be subject to their privacy policy.
CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. These changes will be posted to the site.
COOKIES
Cookies are small text files sent by your browser to a website that you visit. These cookies are stored on your browser and allows us to record specific pieces of information whenever you visit or interact with our sites.
Some cookies have been installed on the basis of consent, this consent can be withdrawn at any time through your web browser. We use cookies for 4 main reasons outlined below:
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Operational necessity. We may use cookies, web beacons, or other similar technologies to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions
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Performance related. We may use cookies, web beacons, or other similar technologies to assess the performance of our website including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging or to improve our website content and services
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Functionality related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing our site. This may include identifying you when you sign into our sites or keeping track of your specified preferences or past items viewed so that we may enhance the presentation of content on our sites
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Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. Our main partner are:
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Facebook - to provide advertising services through Facebook’s advertising and marketing platforms and other social networking plug-ins or marketing tools
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Google Analytics - Google Analytics is an online analytics platform that tracks your interactions with the website. Whilst the cookies are used to identify you as an user, they do not do so with personally identifiable information.
BEHAVIOURAL ADVERTISING
As described above, we use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
FACEBOOK (INCLUDING INSTAGRAM) - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@furthr.earth or by mail using the details provided below:
Furthr Ltd, Kemp House, 124 City Road, EC1V 2NX, United Kingdom