Privacy Policy - UK

Last Updated February 1, 2024

GENERAL

In connection with the issuance of your Gift Card and the management of the Gift Card Program Services, TOTUS GC UK, LTD. (“TOTUS UK”) and our management company, TOTUS Gift Card Management, LLC (“TGCM”) (TOTUS UK and TGCM being hereafter sometimes referred to collectively as “TOTUS”) value the privacy and protection of your Personally Identifiable Information. In the course of interacting with you in the purchase, redemption, and management of your Gift Card, we are necessarily required to collect, use, and share your Personally Identifiable Information. This Policy provides you with information about how we collect, use, and share Personally Identifiable Information.

ABOUT THIS PRIVACY POLICY

This Policy applies to TOTUS (hereafter “TOTUS,” “we,” “our,” or “us”). In this Policy, the words “you” and “your” refer to you, any Cardholder, or other user of our services, as the party agreeing to this Privacy Policy.

Unless stated elsewhere in this Policy, capitalized terms shall have the meaning set out in section 10 below.

This Policy describes choices and rights available to you regarding your Personally Identifiable Information. If you have any questions, please contact us via the channels listed below.

This Policy describes our data privacy practices, procedures and guidelines for information that we collect from you in doing business with TOTUS, including, but not limited to:

Purchase, redemption, refunds, cancellation and other activities we perform in the course of providing our Gift Card Services to you.
Communications with TOTUS, including without limitation, contacting our customer service; connecting, posting, or communicating with TOTUS on social media.
If applicable, use of any software applications made available by TOTUS for use by you on or through computers, tablets, and mobile devices (the “Apps”)
Your use of the Website and any other websites owned or controlled by us, subsidiaries and affiliates.

Unless TOTUS advises you otherwise, this Policy does not apply to your use of any third-party websites accessible through, or to which you may directed by, the Website.

As more specifically set forth below, this Policy also applies to Personally Identifiable Information that we receive from business partners and other third parties in the course of providing our Gift Card Services. You can ﬁnd more information about our collection of Personally Identifiable Information below.

Additional privacy disclosures or policies may apply in connection with your use of a speciﬁc product or relationship you may have with our U.S. business. Please read this Policy and any additional privacy disclosures or policies to understand our views and practices.

1. Acceptance of This Policy

By purchasing or using your Gift Card and/or our Gift Card Services, or using the App or the Website, you are accepting and consenting to the terms set out in this Policy.

2. Personally Identifiable Information We Collect

We obtain various categories of Personally Identifiable Information relating to you from various sources described below:

2.1 Categories of Personally Identifiable Information We Collect

The categories of Personally Identifiable Information that we may collect include:

Identity Information. We may collect identiﬁers, such as ﬁrst name, middle name, last name, maiden name, title, alias, data of birth, place of birth and photographs.
Contact Information. We may collect your email address, telephone number, username, physical address, geolocation information, IP address, delivery address.
Social Media Information. We may collect information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates, and friend list.
Payment Information. We may collect payment information, such as credit or debit card information, bank account information, and billing information.
Demographic Information. We may collect demographic information, such as age, gender, and marital status.
Website/App Activity. We may collect information about how your use the Website and/or App, your internet protocol (IP) address, your login data, browser types and version, time zone setting and location, browser plug-in types and versions, characteristics, device IDs and characteristics, operating system and platform and other technology on the devices you use to access the Website and/or App and referring URLs.
Commercial Information. We may collect commercial information about the products and services you purchase from us and/or use.
Profile Information. Such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Location Information. We may collect location information, such as location based on your IP address or geolocation information.
Audio Recordings. We may collect audio recordings, such as customer service calls and communications.
Text/Chat Content. We may collect chat or text content and history, such as customer care conversations.
Inferences. We may collect inferences regarding your marketing and communications preferences, interests, and other characteristics.

2.2 How and Where We Collect Personally Identifiable Information from You

TOTUS collects your Personally Identifiable Information from you both directly and indirectly in a number of ways, such as:

When You Conduct Business with Us. We collect Personally Identifiable Information from you when you use, visit, or participate in TOTUS activities and interactions. This may include, for example, when you use, purchase, obtain, or consider buying or using a Gift Card or our Gift Card Services, create an account on the Website, subscribe to our publications, requestion marketing to be sent to you, enter a competition, promotion or survey or give us feedback or contact us.
Websites and Social Media. We collect Personally Identifiable Information though the Website and those of our Channel Partners, vendors, suppliers and contractors who oﬀer or support your Gift Card or Gift Card Services, and through social media activities, communications, or postings.
Payment for Services. We collect Personally Identifiable Information from you in order to fulﬁll your Gift Card order and your request for Gift Card Services.
Product or Service Inquiries. We collect Personally Identifiable Information from you in order to respond to your request for a quote or inquiry about our products and/or services, including our promotions, giveaways, sweepstakes, and contests (which may be done in conjunction with Website registration), or if you participate in our promotions.
Customer Service Centres. We collect Personally Identifiable Information from you when you contact us, including when you communicate with us by telephone, email, via the online chat service or contact customer service. These communications may be recorded for purposes of quality assurance and training.

2.3 Another Party’s Personally Identifiable Information

The information that you provide us may sometimes include another individual’s Personally Identifiable Information. Before providing, entering, or submitting Personally Identifiable Information with respect to anyone else, please ensure you have the full authority and permission to do so.

2.4 Personally Identifiable Information Obtained from Third Parties

TOTUS may also collect your Personally Identifiable Information from third parties with whom you or TOTUS have done or are doing business. Some examples are when we collect Personally Identifiable Information from:

Our Affiliates and Business and Marketing Partners. We may obtain your personal information from our affiliates and business/marketing partners, including our Channel Partners, in order to oﬀer and provide a Gift Card and Gift Card Services to you.
Customers. From the Websites, or those of merchants or other third party with which we do business on their behalf for example we manage their Gift Card programmes), we may obtain your Personally Identifiable Information from Cardholders or customers who purchase Gift Cards from merchants with whom we do business for the purpose of delivering the Gift Card to you or the person you nominate to receive it.
Social Media Sign-On/Account Linking. The Websites may include functionality that allows integration with third-party social media sites, such as Twitter, Facebook, Instagram, or other social media sites or networks. Certain of those third-party services may provide us with your Personally Identifiable Information to enhance and personalize your use of the Website. If you submit your credentials (e.g., username and password) for a third-party website or service during your registration on the Website or in connection with updating your user proﬁle, we may receive your Personally Identifiable Information from such third-party website or service.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Location information, Website or App Information from analytics providers such as Google based outside the UK and advertising networks such as Google based outside the UK.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services financial service firms, social media companies that may be based inside or outside the UK.

2.5 Personally Identifiable Information Obtained Passively

When you access the Website, TOTUS and its business/marketing partners and service providers may collect Personally Identifiable Information related to you, as well as processes and programs that are running on your device, by way of the use of “cookies”, web beacons, auto-save programs, and other similar applications and processes. A “cookie” is a small data ﬁle that a website transfers to your computer’s hard drive. A web beacon (also known as a web bug) is clear or transparent image file or series of code used to keep track of your navigation through a single website or series of websites. A web server log is a simple text ﬁle that records activity on the server of the Website in question, such as when and how visitors are accessing a website. Please see the Website Cookie Policy https://blackhawknetwork.com/cookie-policy for further details.

2.6 How We Use Your Personally Identifiable Information

We will only use your Personally Identifiable Information when the law allows us to. Most commonly, we will use your Personally Identifiable Information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your Personally Identifiable Information although we will get your consent before sending direct marketing communications to you. You have the right to withdraw consent or exercise your rights under the data protection laws at any time by contacting us.

TOTUS may use your Personally Identifiable Information provided to us (under one or more of the basis set out above) in the following ways:

To oﬀer and provide our Gift Cards or Gift Card Services and to support our business activities.
To service or fulﬁll purchase orders, including communications with you about your Gift Card or Gift Card Services, send an order conﬁrmation, register and service your account, and respond to customer service requests.
To personalize your experience by displaying content based upon your preferences and personal interests.
To maintain our relationship with you and provide you with information about or changes to the Websites, our Terms of Use, and/or this Policy.
For internal business processes, authentication, loss and fraud prevention, public safety, and legal functions, including reporting to state and federal governmental agencies.
For direct marketing purposes, which may include inviting you to participate in Gift Card competitions, promotions, giveaways, sweepstakes, and contests and sending you information about our existing, new, or future products and/or Gift Card Services or news and information that you have otherwise requested.
To invite you to participate in user surveys or to ask for your feedback on our Gift Cards and Gift Card Services.
For internal statistical, product development, marketing, or operational purposes, such as to measure and understand demographic, user preferences or interests, purchasing, and other market trends among our Cardholders.
To protect the security and integrity of your Personally Identifiable Information and our company operations.
To investigate, prevent, defend against, or take other action regarding violations of our Policy, illegal activities, suspected fraud, or situations involving potential threats to the legal rights of us or others.
To comply with applicable law.

In some instances, we may combine Personally Identifiable Information and other information we collect with oﬄine information, including information from third parties. We may also transfer or disclose your information within our group companies for these purposes.

TOTUS will not use your Personally Identifiable Information for any other purposes unless we notify you, or for which you have speciﬁcally consented to at the time of collection, or as otherwise described in this Policy, or as permitted or required by law.