THE CLUB PRIVACY POLICY

This Privacy Policy applies between You, the user of the Club and Website, and Us, the provider of the Club and Website. We take the privacy of Your Data very seriously. This Privacy Policy applies to Our use of any and all Data collected by Us or provided by You in relation to Your use of the Club or the Website.

This Privacy Policy should be read alongside, and in addition to, the Club User Terms and Conditions, which can be found at Club Terms and Conditions, and the Club Cookie Policy, which can be found at Club Cookie Policy.

Definitions

Appropriate Safeguards: means such legally enforceable mechanism(s) for transfers of personal Data as may be permitted under Data Protection Laws from time to time;

Care: means the help available to deal with Your Club related queries via email at care@mclear.club;

Club: means the membership club offer that allows You to access the Benefits. You may access the Club using the Mobile App or the Website, and You will need an active internet connection to access it.

Cookies: means a small text file placed on Your computer by the Website when You visit certain parts of the Website and/or when You use certain features of the Website. Details of the cookies used by the Website are set out in the Club Cookie Policy;

Data: means all the personal information that You submit to Us via the Club and/or the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Data Protection Laws: means any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR: means the General Data Protection Regulation (EU) 2016/679;

Mobile App: means the mobile application provided by Your Payment Service Provider;

Payment Device: means the payment card or ring, or some such other form-factor, provided by Your Payment Service Provider;

Retailer: means an independent third-party supplier that provides online and/or instore Benefits;

We, Us, or Our: means Rokami Ltd whose registered office is St Michaels Shinfield Road, Shinfield, Reading, Berkshire, England, RG2 9BE, or any of its wholly owned subsidiaries;

Website: means the website www.ringpay.plus;

You: means the person entering into this Agreement with Us.

The Data We collect about You

1. We may collect the following Data, which includes personal information, from You:

1.1 Your name, address, phone number, date of birth, gender, email address, and an anonymous identifier from Your Payment Service Provider;

 

1.2 Your account information: such as Benefits purchased, Your marketing preference status, or any other information related to Your account;

 

1.3 Your contact with Us: such as an email or message that You send to the Care team, or other records of any contact You have with Us;

 

1.4 Your preferences for particular products, services, or lifestyle activities, when You tell Us what they are, and based on how You use Your Payment Device and the Club;

 

1.5 Your use of the Club, Your browsing history within the Mobile App or Website, or Your interaction with an email that We send You. This may include details of Your operating system, location, IP address, browser ID, browsing activity, and other information about how You interacted with the Club. We may collect this information as a part of log filing process, as well as through the use of Cookies or other tracking technologies.

 

2. We DO NOT store, capture, or at any time hold any bank sort code or account numbers relating to Your bank account, credit card, or debit card.

When We collect Your Data

3. We will collect Your Data when You:

3.1 Register with Us and set up the Club;

3.2 Use the Club;

3.3 Subscribe to newsletters or alerts from Us;

3.4 Ask Us for more information about the Club;

3.5 Elect to receive marketing communications from Us;

3.6 Enter a competition or promotion;

3.7 Redeem a Benefit;

3.8 Share any part of the Club on social media where the social media privacy rights in force allow this to occur;

3.9 Leave a comment on one of Our blogs;

3.10 Contact Us with a question or a complaint;

3.11 Complete surveys that We use for research purposes (although You are not obliged to respond to them);

3.12 Visit or browse the Website or third-party supplier websites. We automatically collect some information about Your visit to the Website. This information helps Us to make improvements to Website content and navigation, and includes Your IP address, the date, times and frequency with which You access the Website and the way You use and interact with its content. We collect Your Data automatically via Cookies, in line with the settings on Your browser.

4. We may also collect information about You from other organisations, if this is appropriate: these include fraud-prevention agencies, business directories, other companies, or Our third-party suppliers.

 Using Your Data

 5. Rokami and Our third-party suppliers may use, process, and analyse Your Data to:

5.1 Provide the Club to You;

5.2 Respond to any questions or concerns You may have about using the Club;

5.3 Monitor the performance of Club campaigns;

5.4 Subject to You opting-in to receive marketing communications, occasionally keep You informed about new products and services from Rokami and carefully selected third-party suppliers;

5.5 Understand how You use The Club to develop more interesting and relevant products and services, as well as personalising the products and services offered to You;

5.6 Carry out research and statistical analysis on an anonymous and aggregated basis based upon how You use the Club;

5.7 Provide anonymous aggregated trend analysis data-points to third parties (such reports do not contain any information which may identify You as an individual;

5.8 Prevent and detect fraud or other crimes, recover debts, or trace those who owe Us money.

6. Your Data will be stored for as long as required by law in order to provide You with the Club. Some of Your Data will be kept for a reasonable period after this Agreement has finished in case You decide to use the Club again. You may be contacted during this time if You have opted-into receiving marketing communications from Us.

7. In supplying this Data, You consent to this information being collected, used, disclosed, stored by Us, and if necessary to provide the Club, transferred to Our third-party suppliers.

8. Any comments or information that You supply on any blog that Rokami operates can be read, used or collected by anyone. If Your information appears in Our blog pages and You want it removed, please contact the Care team.

9. We maintain presences on social media platforms including Facebook, Twitter, and Instagram. Your interactions with these platforms are governed by the privacy policies of the companies that provide them. Anything You submit to Rokami via a social media platform is done so at Your own risk without any expectation of privacy.

 Sharing Your Data

 10. We may share Your Data with:

10.1 The third-party suppliers that We use to provide You with the Club;

10.2 Fraud prevention agencies, law enforcement agencies, regulatory organisations, courts or other public authorities if We have to, or are authorised to by law, to facilitate the detection of crime or the collection of taxes or duties.

11. To ensure that Your Data receives an adequate level of protection, We have put in place Appropriate Safeguards and procedures with the third-parties We share Your Data with. This ensures Your Data is treated by those third-parties in a way that is consistent with the Data Protection Laws. We may transfer Your Data to third-party suppliers in countries outside of the European Economic Area (EEA). This happens when Our third-party suppliers are based outside the EEA, or if You use the Club while visiting countries outside of the EEA. We will only transfer Data outside the EEA where it is compliant with Data Protection Laws.

12. We may, from time to time, expand or reduce the size of Our business. If We are reorganised or sold to another organisation, We may transfer Your Data to that organisation. We may also disclose Your Data to a prospective purchaser of Our business or any part of it. In these instances, We will take steps to ensure that Your privacy is protected. 

 Keeping Your Data secure

 13. We constantly review and improve measures to protect Your Data from unauthorised access, accidental loss, disclosure, or destruction. If You suspect any misuse or loss or unauthorised access to Your Data, please let Us know immediately by contacting the Care team.

14. Where We have contracts with third-party suppliers to provide Us with services to process Your Data, We ensure they have appropriate security measures in place, and only process Your Data in the way We have authorised them to.

15. The Club may contain links to enable You to visit other websites and apps of interest easily. These linked websites and apps are not under Our control and once You have used these links to leave the Website or the Mobile App, You should note that We do not have any control over that other websites or apps. Therefore, We cannot be responsible for the protection and privacy of any information which You provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website or app in question. We advise You to examine the terms and conditions of using that website or app and its privacy statement. We do not make any representations about third-party websites or apps that may be linked to the Website or the Mobile App.

16. Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered – as this is the nature of the internet. We can’t accept responsibility for any unauthorised access or loss of Data that’s beyond Our control. 

 How to access and control Your Data  

17. It is important that the Data We hold about You is accurate and current. Please keep Us informed if Your Data changes during the period for which We hold it. If You have any questions about the Data We hold about You, or if You believe We’re holding inaccurate information about You, please contact the Care team.

 Your rights

 18. Under the General Data Protection Regulation, You have a number of important rights, which include but are not limited to:

18.1 the right to be informed;

18.2 the right of access;

18.3 the right to rectification;

18.4 the right to erasure;

18.5 the right to restrict processing;

18.6 the right to Data portability; and

18.7 the right to object.

19. If You would like to exercise any of Your rights, please email the Care team. In order to identify You, We’ll need to receive proof of Your identity and address (a copy of Your driving licence or passport and a recent utility or credit card bill), and You’ll need to let Us know what Data the request relates to.

 How to make a complaint

 20. We will always try to resolve any query or concern You raise with the Care team about Our use of Your Data. However, if You wish to log a complaint with the United Kingdom Information Commissioner under the General Data Protection Regulations, they may be contacted at https://ico.org.uk/make-a-complaint/.

 Changes to this Privacy Policy

21. This Privacy Policy was published on 18 05 2020.

22. We may change this Privacy Policy from time to time by giving You at least a month’s notice before the changes take effect. When We make changes, We will inform You via email. You have the right to cancel Your Club membership at any time before the changes come into effect. If You do not cancel your Club membership, You will be treated as having accepted the changes.

 

 

RAISR SERVICE COOKIE POLICY

We use cookies and similar tools on the Website to improve their performance and enhance Your user experience. This policy explains how We do that. 

What are cookies?

1. Cookies are small text files which a website may put on Your computer or mobile device when You first visit a site or page. The cookie will help the website, or another website, to recognise Your device the next time You visit. Web beacons or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way. 

 What sort of cookies does the Raisr websites use?

2. The Website uses the following cookies:

2.1 Necessary cookies. These cookies are absolutely essential for the Website to function properly, and for You to use its features. As these cookies are strictly essential to the operation of the Website, We do not need to ask for Your consent to use them. These cookies do not store any personal Data.

2.2 Non-necessary cookies. These cookies analyse how You use the Website and allow Us to monitor performance. We always ask for Your consent prior to storing these cookies in Your browser.              

 Can a user block cookies?

3. As explained in clause 2 above, cookies help You to get the most out of the Website. However, if You do wish to disable Our cookies then please follow the instructions here http://www.allaboutcookies.org/manage-cookies/

4. Please remember that if You do choose to disable certain cookies, You may find that certain parts of the Website do not work properly.          

 More Information

5. More detail on how businesses use cookies is available at allaboutcookies.org

6. If You have any queries regarding this Raisr Service Cookie Policy please contact the Care team.